EHR certification: Is the latest standard attainable?

The Centers for Medicare & Medicaid Services (CMS) wants physicians to use 2015-certified EHRs,  an upgrade that CMS officials believe will help providers more easily share patient information.

Requiring the use of these up-to-date EHRs comes after CMS redesigned its incentives under the Merit-based Incentive Payment System (MIPS), which is part of Medicare’s value-based-pay program affecting many physician practices.

Yet CMS and health IT experts estimate that thousands of physicians have yet to switch to 2015-certified EHRs. This scenario could leave those physicians scrambling in the coming months to make potentially costly and complex EHR upgrades. The alternative is to risk lower MIPS scores for 2019, which could mean lower Medicare reimbursements.

As a result, some health IT experts see the government’s push for physicians to update their systems as unduly burdensome.
“There’s a big group of physicians who haven’t made a switch to the new software, and those who aren’t on the 2015-certified EHRs are usually the small and independent practices,” says Robert Tennant, MA, director of health IT policy for the Medical Group Management Association, headquartered in Englewood, Colo. “We don’t want to impose such a hardship on these practices just to get them on some arbitrary standards with their EHRs that may not even produce higher quality of patient care.”

Federal requirements drive EHR upgrades

MIPS mandates physicians to use EHRs certified to have specific features and functions established under the federal government’s 2015 Edition Health IT Certification Criteria.

After months of discussion, CMS is finalizing its 2019 Medicare Quality Payment Program rules and is expected to approve the requirement for physicians to use 2015-certified electronic health records (EHR) systems in order to be eligible to receive the maximum MIPS score.
Many vendors have their 2015-certified EHR updates ready for physicians to implement, according to healthcare IT experts. And many medical facilities and physician practices already have implemented these updated systems.

In fact, the Office of the National Coordinator for Health Information Technology reports that 80 percent of clinicians have access to 2015-certified EHRs, with experts explaining that many EHR vendors don’t yet  have certified EHRs ready for the physicians using their technology.
But access to 2015-certified EHRs is not the same as having those upgraded systems implemented and in everyday use, says Jeff Coughlin, MPP, senior director of federal and state affairs at the Healthcare Information and Management Systems Society (HIMSS), a nonprofit health IT advocacy organization.

Indeed, the estimated number of upgraded EHRs actually implemented is lower: ONC earlier this year reported that at least 66 percent of clinicians eligible to participate in MIPS have 2015-certified EHRs.

Heath IT leaders say that’s a healthy track record of adoption, but they stress that the ONC figure means that one-third of the roughly 750,000 physicians in the United States don’t have the updated EHRs they’d need to meet these new CMS requirements.

Health IT experts say that physicians with EHR vendors who have yet to receive certification for their products (mostly the smaller and niche companies) and small practices without strong IT support services will be more likely to face such struggles than practices using EHRs from the bigger vendors and/or those practices affiliated with medical centers with IT departments handling the work.

Interoperability behind push for new certification

Physicians will still be able to practice without the 2015-certified EHRs; in fact, CMS is expected to require physicians use the updated version for only a 90-consecutive- day reporting period in 2019, which CMS officials say gives physicians time to implement the upgrades.

But Tennant says physicians will be hard-pressed to meet some of the anticipated reporting requirements for 2019 without a 2015-certified EHR in place and they will not be able to optimize their MIPS scores without having the upgraded version in place and fully utilized for at least one quarter of the upcoming year.

He says physicians could miss out on meeting requirements under Promoting Interoperability-one of four categories that make up the MIPS score-by not having a 2015-certified EHR in place. Moreover, physicians also might not be able to meet all the requirements under the Quality category without an updated EHR in place for the entire year.

Tennant says CMS should recognize that requiring this EHR upgrade is a hardship for many practices, pointing out that some physicians can’t afford the costs associated with implementing updated software while those whose vendors have yet to release a 2015-certified version are struggling to decide whether to wait or go the more costly route of finding  a new EHR vendor. He says his organization suggests CMS continue encouraging practices to move to 2015-certified EHRs while still allowing physicians to use their current versions without risking lower MIPS scores.

Still, many health IT leaders say they support the goals of the 2015 certification. “We’re big boosters of the 2015-CEHRT,” Coughlin says. “We talk about interoperability, and the steps and benefits included with the 2015 changes really promote greater data exchange.”

Significant work required for ­upgrades

Physicians should anticipate a lot of work and potential extra costs associated with that work.

“An upgrade always takes longer than anyone anticipates, because there’s never anything seamless about something like this. And this is a major upgrade,” says Mari Rose Savickis, MPA, vice president of federal affairs with the College of Healthcare Information Management Executives (CHIME).

Tennant says the work involved in an upgrade varies based on numerous factors. Physicians with an EHR using an on-site server will likely need their vendor to come on-site to update the systems, while vendors offering cloud-based EHRs will be able to remotely upgrade the systems of their physician customers.

Physicians also will find that whether, and how much, a vendor charges for its 2015-certified EHR updates can vary, depending on their contracts, whether they’re on the most current version of their vendor’s EHR software or have skipped previous upgrades, and other factors, Tennant adds. They should expect moving to 2015-certified EHRs possibly to require re-working certain processes or adjusting to new user interfaces.  

As a result, physicians need to build in time to train themselves and their staff on their upgraded EHRs,  which could mean everything from learning how to navigate new screens to tweaking workflows, says Brooke Rockwern, MPH, an associate of health IT policy at the American College of Physicians.

Experts advise that physicians also plan for a reduced number of patients following implementation as they get accustomed to their new systems in addition to the downtime scheduled for actual training.

A sense of urgency

Physicians who don’t yet have a 2015-certified EHR in place need to determine if their existing EHR vendor has one available, Savickis says, noting that the government provides an online list of certified health IT products at https://chpl.healthit.gov/#/search.

If a vendor doesn’t yet offer a 2015-certified EHR, the physician needs to find out whether it will soon have one available. If the vendor doesn’t, the physician will need to find a different vendor and plan to take out the existing EHR and replace with a new one-a significant undertaking, Savickis says.

Some physicians might find, for example, that they need to upgrade some hardware; they might need new servers if they’re using server-based EHRs, or they might need new computers powerful enough to handle the upgraded software.

Savickis says physicians need to ensure their 2015-certified EHRs are fully tested to ensure everything works properly and securely. This process could reveal that the EHR doesn’t work well with other software systems, a glitch that will require additional technical work and testing to solve.

Additionally, physicians should anticipate a possible time lag in implementing the upgraded version of their EHRs, Rockwern says. Even if a physician or practice is ready to implement upgrades, the vendors, IT consultants and technical workers it needs might have a backlog of work as other providers get ready for the new CMS requirements

However, health IT experts say they expect CMS to provide hardship exemptions for physicians who aren’t ready in time.

Still, Tennant, Rockwern and others say that despite physicians’ frustrations over the years about their EHRs and government mandates around the use of technology, they believe the requirements for 2015 certification will bring improvements through improved interoperability capabilities, increased security features, a greater ability to incorporate patient-generated health information and more capacity to analyze patient demographic data to identify trends.