Medicare Compliance & Reimbursement

Question: We’re a little confused by the updated information on EHR requirements for MIPS-eligible providers under the Promoting Interoperability performance category for 2024. Did something change? Is the 2015 Edition CEHRT different now?

Ohio Subscriber

Answer: It’s more a case of the Centers for Medicare & Medicaid Services (CMS) tweaking the requirement and redefining it than an actual major change.

For the 2024 performance period, CMS opted to change the definition and parameters for the Merit-Based Incentive Payment System (MIPS) EHR requirement in the Promoting Interoperability category to better align with Office of the National Coordinator for Health Information Technology (ONC)’s updates.

“In a recent proposed rule, ONC proposed to move away from the ‘edition’ construct for certification criteria,” CMS explains in its calendar year (CY) 2024 Medicare Physician Fee Schedule final rule guidance for MIPS. “Instead, all certification criteria will be maintained and updated at 45 CFR 170.315. We’re aligning our definitions of CEHRT for [Quality Payment Program] QPP and the Medicare Promoting Interoperability Program with the definitions and requirements ONC currently has in place and may adopt in the future,” CMS reiterates.

Resource: Review the regulation 45 CFR 170.315 at www.ecfr.gov/current/title-45/subtitle-A/subchapter-D/part-170/subpart-C/section-170.315.