New CMS Reporting Options for Decertified EHRs

May 4th, 2017 - By Matt Garnese

On April 28, the CMS published a new rule in the Federal Register regarding EHR reporting. The rule comes in response to the call from the Health IT community to relax some of the more stringent policies regarding quality data reporting. As PrognoCIS continues to maintain all necessary current certifications, we are only posting this information for our customers to pass along to their colleagues should they find themselves in the situation described below.

The proposed rule is a revision of Medicare inpatient prospective payment systems (IPPS), and implement statutory provisions of current legislation, such as MACRA and the 21st Century Cures Act. The CMS proposes to add new payment adjustment exemptions from Medicare for Eligible Professionals (EPs), Eligible hospitals (EHs), and Critical access hospitals (CAHs) with decertified EHRs. These groups will be exempt from payment if they can demonstrate that they cannot meet the requirements of a meaningful EHR because their previously certified EHR technology (CEHRT) was decertified under the Office of the National Coordinator for Health Information Technology’s (ONC) Health IT Certification Program.

The rule also states that EPs, EHs, and CAHs will qualify for the exception as long as their CEHRT was decertified before or during the applicable EHR reporting payment adjustment period for 2018, during a continuous 90-day period in either 2016 or 2017, depending on whether the EP/EH/CAH successfully demonstrated meaningful use in a prior year.

The CMS will maintain the section of the Cures Act that states that “in no case may an EP, eligible hospital, or CAH be granted a hardship exemption from the payment adjustment based on significant hardship or decertified EHR technology for more than five years.”

What To Do If Your CEHRT Was Decertified

On the CMS website they have a FAQ which gives a few details for EPs/EHs/CAHs with a decertified EHR. Here are some key points:

  • If the EHR was decertified after your EHR reporting period ended, you can still use that product.
  • If the EHR was decertified before your EHR reporting period ended, you can apply for the hardship exemption as mentioned above.
  • If the hardship exemption period is already closed for the applicable payment adjustment year, contact the CMS Hardship Coordinator (

What to Expect for Future Reporting Requirements

As reported in a recent article by FierceHealthcare about the new rule, this legislation is a continued demonstration of flexibility from the federal government with regard to quality reporting in response to providers who have called for less stringent reporting requirements and have resisted the transition to Meaningful Use 3.

The new rule allows health care providers to avoid penalty while continuing in the effort to move away from a fee-for-service care model and towards value-based care.

For PrognoCIS customers, who may have heard from fellow providers affected by the decertification of their EHR, we would welcome any referral engagements to ensure their colleague’s practice stays up to date in using an EHR which keeps pace with current requirements. To reiterate: PrognoCIS is up-to-date with all currently required certifications as has been our practice in serving the solo, small practice and enterprise community for over 10 years.

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