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The bad news about CMS's planned delay to the EHR upgrade mandate

July 6, 2017

    CMS last month in its much-anticipated 2018 Quality Payment Program (QPP) rule proposed to delay the deadline for when Medicare providers must complete their 2015 Edition certified EHR technology (CEHRT) upgrade.

    Originally, CMS had planned to require all QPP participants (i.e., those in the Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Model (APM) tracks), to use only 2015 Edition CEHRT in program year 2018. 

    But CMS changed course in the new proposed rule: It now plans to permit 2014 Edition CEHRT, the 2015 Edition, or a combination of the two next year.

    Good news or bad news?

    This may sound like good news for QPP participants: they wouldn't have to rush any implementation timelines, and they could get more mileage out of the 2014 Edition software they invested in.

    But here's why it could this also be bad news: This marks the first time that CMS may not align CEHRT requirements between quality reporting programs.

    Under the 2018 Inpatient Prospective Payment System (IPPS) proposed rule released by CMS in April, hospitals that participate in the Inpatient Quality Reporting and Meaningful Use (MU) and eligible professionals (EPs) that report Medicaid MU would have to upgrade and use only 2015 Edition CEHRT in program year 2018.

    According to CMS, trends in certification timing for vendors and availability of 2015 Edition CEHRT upgrades are enough to justify these differences in CEHRT requirements. An Office of the National Coordinator for Health IT (ONC) analysis suggests that 2015 Edition CEHRT will be available to 85% of hospitals and 74% of QPP participants, respectively, by 2018. Additionally, a large majority of hospitals use CEHRT from the top five developers (according to market share). Ambulatory providers, on the other hand, use CEHRT from a wider range of developers, and the certification and testing readiness of these developers is not universal.

    Should CMS choose not to align the CEHRT requirements, there would be several challenges for providers:

    • The time it takes to test, deploy, debug, learn, and fully adopt new functionalities has a "long tail." The 2015 Edition, for instance, has completely new, advanced capabilities with which providers would have little to no experience.

    • EPs that report Medicaid MU may be subject to QPP provisions if they treat Medicare patients. For such providers, there are two different sets of measures (MU versus MIPS Advancing Care Information [ACI]) to track, with MU measures significantly harder to achieve than the more flexible ACI set.

    • Health systems that manage both hospital and ambulatory quality programs would have to monitor very different sets of requirements for ACI and hospital MU.

    • QPP participants that work in both the hospital and office-based settings could get very confused. If they don't have to upgrade to the same time frame as hospitals, they would find the office-based EHR does not report similar measures.

    CMS is expected to release its 2018 IPPS Final Rule in the first full week of August, which we anticipate will provide clarity on whether the EHR upgrade mandate discrepancy will stand, or whether it will be aligned with the 2018 QPP proposal.

    If the IPPS rule brings alignment, you will be able to breathe a sigh of relief and at least take comfort in the same upgrade deadline between programs. If alignment does not occur, we suggest health systems fast-track 2015 Edition CEHRT implementation plans for QPP participants so they can reduce their overall reporting complexity with similar ACI and MU measure sets for all provider types.

    What you can do right now

    In the meantime, please plan to join me and my fellow Advisory Board Research colleagues for a webconference on Tuesday, July 11, at 3:00 p.m. ET, as we discuss the finer details and larger strategic implications of the 2018 QPP proposal.

    We'll provide an overview of the most important implications of the proposed rule for provider organizations; a review of key changes to the MIPS and APM tracks for the 2018 performance year; and guidance on navigating the transition to risk-based payment and the evolution of hospital-physician alignment.

    Register Now

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