Clarifying Certification Requirements for Hospitals

With all the changes happening to Meaningful Use, Quality Measurement, and MACRA in 2016, I’ve been asked many questions by many organizations to help them plan for the future.

As I’ve said many times, one of the great challenges we have is that the 2015 Edition final rule has an enormous scope extending beyond Meaningful Use with the notion that it can be coupled to every government healthcare IT program.    Standards needs to be based on requirements and specific use cases with little optionality, so creating a broadly scoped rule before the use cases are known just doesn’t work.   Although it is my hope that the tight coupling of the 2015 Edition final rule to various programs will be eliminated eventually,  it is important to understand what certifications are needed for what programs in 2016, 2017 and 2018.

For example, all current BIDMC systems are certified to the 2014 Edition.    Will we be able to participate in government programs in 2016 using the 2014 Edition Certification?  Yes!    Will we be able to participate in government programs in 2017 using the 2014 Edition Certification?  Yes!    Only in 2018 will we have to be certified to the 2015 Edition and we can all hope that the certification concept is revised before then.

Here’s an example of the actual language in regulations illustrating certification requirements.  Please find below rule text excerpts and citations to the Hospital Inpatient Quality Reporting Program’s EHR certification requirements for electronic clinical quality measures (eCQM) reporting.

For the CY 2016 reporting period (FY 2018 payment update), use the 2014 or 2015 edition:

From the FY 2016 IPPS final rule (80 FR 49705-6):

“In the FY 2016 IPPS/LTCH PPS proposed rule (80 FR 24587), we proposed to continue the requirement for hospitals to use CEHRT 2014 Edition when submitting electronic clinical quality measures for the CY 2016/FY 2018 payment determination. However, in response to comment suggesting that hospitals be allowed to report using either the 2014 or 2015 edition of CEHRT, we are finalizing a modification to our proposal such that, for CY 2016/ FY 2018 payment determination reporting of electronic clinical quality measures, hospitals can report using either the 2014 or 2015 edition of CEHRT.”

For the CY 2017 reporting period (FY 2019 payment update), use the 2014 or 2015 Edition:

From the FY 2017 IPPS final rule (81 FR 57170):

“After consideration of the public comments we received, we are finalizing that hospitals must report using EHR technology certified to either the 2014 or 2015 Edition for the CY 2017 reporting period/FY 2019 payment determination (not subsequent years) as proposed.  We also refer readers to section VIII.A.10.d.(5) of the preamble of this final rule, in which we finalize alignment of this policy in the Medicare and Medicaid EHR Incentive Programs.”

For the CY 2018 reporting period (FY 2020 payment update), use the 2015 Edition:

From the FY 2017 IPPS final rule (81 FR 57171):

“After consideration of the public comments we received, we are finalizing the required use of EHR technology certified to the 2015 Edition for the CY 2018 reporting period/FY 2020 payment determination and subsequent years as proposed. We also refer readers to section VIII.A.10.d.(5) of the preamble of this final rule, in which we finalize alignment of policies in the Medicare and Medicaid EHR Incentive Programs.”

I hope providers and developers find this useful.    In the next few years, we can hope that the entire QRDA quality reporting standard is replaced by a FHIR implementation guide or at the very least, the need to use QRDA Category 1 (individual patient data submissions) is eliminated.