6 Comments
Sep 13Liked by Brendan Keeler

Amazing as always. I learned a ton from this one!

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Jun 24Liked by Brendan Keeler

Great (& dense) article. But it didn't answer one question. If you submit Medicare claims to CMS, does anyone actually ask you to prove that you used a Certified EHR? Seems to be plenty of cases where CMS says one thing and everyone ignores it (access to patient data & transparent pricing are 2 that come to mind). Eventually CMS may make an example or one or two hospitals. I wonder if anyone is really watching this...

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author

CMS definitely not asleep at the wheel here - there's a ton of publicly available data showing that they are tracking providers and adjusting payment as part of MIPS and Medicare Promoting Interoperability: https://www.healthit.gov/data/datasets/certified-health-information-technology-reported-clinicians-promoting

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Interesting to know

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Great article Brendan!

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Great detail. Thanks for posting. CMMI models require the use of CEHRT using verbiage like this "Use an electronic health record platform that meets CMS and Office of the National Coordinator

for Health Information Technology (ONC) standards for Certified Electronic Health Record

Technology (CEHRT) as defined at 42 CFR 414.1305."

I would argue that "use" is not defined and leaves room for interpretation. For example a VBC company needs a longitudinal care record to be able to perform. So if they use a platform headless ERH solution and then upload all encounter notes into a certified EHR is that still "using" CERHT? would love thoughts

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