Will EHRs Implement the 2015 Edition Cures Update By the Deadline?

Electronic health record (EHR) companies have their single biggest technical update to complete by September 2023, as announced in a recent a meeting with the Deputy National Coordinator of Health Information Technology.  All EHR enhancements that are required to comply with the 2015 Cures Act standards must be completed by September 2023.   All data that is shared must be normalized by that time and EHR technology vendors are required to certify with real world testing.  

According to the Certified Health IT Product List (CHPL) website, as of September 2022, only seven percent of EHRs have completed this certification.  While this covers a larger percentage of certified electronic health record technology (CEHRT) users (since the certified technologies are widely used), most EHRs have a way to go.  In addition, then the 2023 requirements need to be addressed, along with real-world testing in the coming year.

The Office of the National Coordinator for Health Information (ONC) released the 2015 Edition Cures Update which requires EHRs to meet a series of interoperability standards in 2022 and 2023.  The intent of these rules is to allow data to flow more freely to patients and to their providers. This new, standards-based API will enable plug-and-play interoperability and underpin an emerging API ecosystem that will foster applications for patient access, care coordination, clinical research, public health, and population health management.

* Reference the 2015 Cures Act Update for more details on the above requirements

The 2015 Edition Cures Update identifies and requires the use of technical standards, including the use of both HL7 Fast Healthcare Interoperability Resources Specification (FHIR®) Release 4, and the HL7® CDA® R2 Implementation Guide: C-CDA Templates for Clinical Notes STU Companion Guide (C-CDA Companion Guide) to support the USCDI. Additional new standards include the use of NCPDP SCRIPT Standard, 2017071 for electronic prescribing and the SMART on FHIR Application Launch Framework Implementation Guide for Standardized APIs.

In addition, as part of the new Information Blocking Condition of Certification, Certified Health IT Developers are prohibited from information blocking. Until the October 6, 2022 compliance date, electronic health information (EHI) for information blocking purposes is limited to the EHI identified by the data elements represented in the United States Core Data for Interoperability (USCDI) standard adopted in 45 CFR 170.213. On and after October 6, 2022, EHI is defined in 45 CFR 171.102. For more information about this requirement, please refer to the Condition of Certification: Information Blocking Fact Sheet and the Information Blocking CCG.

Finally, the 2015 Edition Cures Update establishes new Conditions and Maintenance of Certification requirements, including new requirements for Real World Testing, Application Programming Interfaces (APIs), Communications, and Attestations. These requirements apply to the actions and behaviors of Certified Health IT Developers as well as their Certified Health IT Modules. While some of the Conditions and Maintenance of Certification requirements began in 2021, several new and additional requirements will be enforced in 2022.

If you are part of the 93% not yet certified for 2022 standards, and you still face the 2023 requirements, you have your work cut out for you.

While you, as a certified EHR technology, work to maintain and succeed at the evolving certification requirements, additional requirements and updates are occurring in the QPP Merit-based Incentive payment Program (MIPS).  The new MIPS Value Pathways (MVP) framework goes into effect in 2023, Promoting Interoperability and Quality measures are updated, health equity factors are being incorporated, and thresholds are evolving.  Supporting your providers in this program is becoming more difficult as CMS raises the bar for avoiding penalties and achieving incentives.   

Supporting the new 21^st Century Cures Act and supporting the evolving QPP requirements in tandem requires significant effort on both fronts. EHRs will be most successful when their development strategies include plans to meet requirements for both the Cures Act and QPP 2023 requirements, or partner with solutions to help them accomplish one or both goals.

Healthmonix is uniquely positioned to support EHRs and their clients in their value-based care journey and keeping up with QPP requirements. Learn more about how we integrate with EHR partners to drive increased MIPS performance and scores, as well as how we are preparing for upcoming challenges such as MVPs.