An array of provider associations have asked federal officials to delay 2015 EHR (electronic health record) certification requirements (CEHRT) “until such technology is widely available, and in no event, sooner than January 2019.”
The American Medical Association (AMA)-led letter to Centers for Medicare & Medicaid Services (CMS) Acting Administrator, Patrick Conway, M.D., and to Office of the National Coordinator for Health IT acting lead, Jon White, M.D., sent this week, noted that starting in 2018, programs such as the Quality Payment Program and Meaningful Use require the use of 2015 Edition technology, beginning in 2018. Although 2014 Edition technology was permitted for use in those programs for this year, the rules call for the updated edition starting next year.
The letter stated, “While over 16 months have passed since the ONC released the final 2015 Edition requirements, few vendors have fully upgraded their systems—only 54 of the over 3,700 products are currently certified and posted on the Certified Health IT Product List (CHPL). Importantly, the vast majority of the certified 2015 Edition products are from a small number of vendors. Requiring physicians to upgrade to 2015 Edition technology by 2018 limits choice by forcing physicians to select a system from approximately one percent of existing products.”
To this point, regarding which vendors currently have 2015 certified products and which don’t, a recent Politico Morning eHealth report noted that “Notable EHR vendors like athenahealth, Cerner, Practice Fusion, NextGen and General Electric are absent from ONC’s website listing 2015 products. A Cerner spokeswoman says the company will begin testing with ONC starting next month. Epic has 10 versions of its 2015 edition software OKed by ONC. Allscripts has another six, and McKesson one.”
Meanwhile, the associations’ letter continued, “In addition, physicians may be driven to switch vendors and utilize a system that is not suitable for their specialty or patient population due to this tight timeline. This is not only contrary to the purpose of an EHR—a tool to help physicians respond to patient care needs—but also jeopardizes a physician’s chance of success in the QPP and MU. Physicians should not be subject to financial penalties under the QPP and MU because vendors have not certified their 2015 Edition products in a timely manner.”
The associations acknowledge that that the 2015 Edition contains functionality that may improve data access, integration of patient-generated health data, and document sharing, initial implementation and utilization of these new tools may prove complex. However, they stated, “We are concerned that requiring the use of 2015 Edition CEHRT by 2018 will result in rushed upgrades, installations, a lack of user training, and an overall disruption to physicians’ practices. As such, physicians should identify their own 2015 Edition-rollout timeline independent of federal regulation.”
Specifically for the Medicare Access and CHIP Reauthorization Act of 2015’s (MACRA’s) Quality Payment Program, which applies to eligible Medicare physicians, many of these small and solo practices do not have the time or resources for these technology upgrades. As such, the letter stated, “To assist these practices, CMS should continue to allow the use of both 2014 and 2015 Editions and permit participants to meet modified Stage 2 MU and Advancing Care Information (ACI) measures.”
The provider association groups concluded that while the 21st Century Cures Act outlines a number of EHR certification improvements in the law, those protections will not be in place before vendors develop, test, and certify 2015 Edition products.
