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...
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
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...
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
Interesting to know
Great article Brendan!
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