Commercial risk will be a critical catalyst of progress – it’s complicated, but is it possible? We think so.

Blog Post

So you've implemented 2015 Edition CEHRT, now what?

December 3, 2019

    This year was a big year—2019 was the first year that 2015 Edition CEHRT was required across several CMS programs, including the Promoting Interoperability (PI) program and the Merit-based Incentive Payment System (MIPS) program. As IT leaders, you were responsible for the implementation of 2015 Edition CEHRT. With multiple stakeholders and many moving parts, this has been a difficult task, and many organizations are still in the process of optimizing their systems.

    Dec. 5 webinar: Get the details of the 2020 QPP requirements

    As we transition into the new year, it's time for IT leaders to identify potential issues to watch out for so that they can set their organizations up for success in 2020. Here's where you should start:  

    Health information exchange

    A main area of focus in PI is to encourage provider-to-provider health information exchange (HIE). However, many providers find it challenging to perform well on the HIE measures. In fact, many plan to take the 2019 exclusion for the Receiving and Reconciling Health Information measure due to technical and/or workflow issues involving their EHRs. Looking ahead, there is no exclusion in 2020 for this measure, so IT leaders must work closely with providers to identify ways to reduce burden in the workflow and improve performance.

    To help providers think through their strategy on this measure, we created our Practical Guide to Success for the Most Challenging Promoting Interoperability Measures. This resource provides key compliance requirements and tips to boost performance. For example, we outline a step-wise approach to clinical information reconciliation. It works like this:

    • First, providers review and validate the clinical information to determine if an update to the patient record is necessary;

    • If an update is necessary, they incorporate the updated information into the record; and

    • If no update is necessary, the provider can document that no update was necessary and mark as reviewed.

    This guide helps streamline the reconciliation process and reduce burden for the care team. We include many other helpful tips in our guide, and we encourage IT leaders to work closely with their clinical leaders on which approaches may help maximize their performance.

    Electronic Clinical Quality Measures (eCQMs)

    Beyond meeting PI reporting requirements, many providers also use the EHR to collect electronic Clinical Quality Measures (eCQMs) data for MIPS Quality reporting. Providers must satisfy data completeness requirements to earn full credit for their Quality measures, and for 2020, CMS increased the data completeness threshold to 70% of all eligible instances per measure. Meeting this requirement shouldn't be an issue for provider groups that use a single EHR. But, it can get complicated when multiple EHRs are involved.

    There are many scenarios where eCQM data are collected in more than one EHR, such as switching EHR systems mid-year. Providers must rely on their IT leaders to aggregate data from across those systems because CMS does not allow eCQM data to be manually added together. During the process to retrieve and combine data from all EHRs sometimes there are technical issues that can get in the way. 

    In the event that it's not possible to aggregate data from across all systems, IT leaders can play a role in mitigating the risk of not meeting the data completeness requirement. For example, when transitioning to a new EHR, IT leaders could consider scheduling the go-live date towards the beginning or the end of the year. That way, if 70% of the eCQM data is collected in the EHR system that was in use for most of the year, providers could still meet the data completeness requirement. Certainly, providers should always strive to combine and report data from all EHRs if possible, but this allows them to have a contingency plan in case they run into issues.


    Get the details of the 2020 QPP requirements

    Join us on December 5 to learn more about strategies to meet data completeness requirements and tips for preparing for the 2020 reporting period.

    Register Now

    Next, get a practical guide to success for the most challenging PI measures

    We've compiled Promoting Interoperability best practices into a practical guide for success. This resource addresses key compliance requirements and tips to boost performance.

    Download Now

    Have a Question?


    Ask our experts a question on any topic in health care by visiting our member portal, AskAdvisory.