The CMS Quality Payment Program (QPP) is a mishmash of complex measures, scoring, and acronyms (like QPP, MIPS, CEHRT). Confusion is perhaps the only constant when talking about maximizing performance in this ever-evolving program. One element which requires attention by virtue of how CMS “labels” the item is CEHRT, the acronym for Certified Electronic Health Record Technology. CEHRT was a designation assigned to certain electronic medical or health record (EMR/EHR) platforms meeting government-defined criteria. Not all EMR/EHR products are CEHRT. However, through Meaningful Use, providers implementing CEHRT products had access to incentive money from the government.
Under the QPP, the CEHRT bonus is a misnomer in that some might think just using a CEHRT product affords an opportunity for the “CEHRT Bonus.” Just reading the entire, formal title of the potential bonus category affords clarity. The “CEHRT End-to-End Electronic Reporting” means just that; i.e., electronic capture and reporting throughout the entirety of the process. In other words, disallowed is any manual intervention (e.g., MS Excel spreadsheet completion, loading of typed files, etc.). Simply stated: the measure data capture and submission to CMS must be an electronic process from start to finish.
On page 30 of the following link, CMS lists “Quality Performance Score: Bonus Points” under which up to 5% (one (1) per measure) is available for “CEHRT Bonus” with a summary to the left of the header that says “Bonus for EHR Reporting.” The ambiguity is clear. However, at the risk of redundancy, just using CEHRT technology does not the bonus afford.
To qualify for the CEHRT End-to-end Electronic Reporting, providers must:
· Use CEHRT to record measure demographic and clinical data elements.
· Electronically export & transmit data to a 3rd party or directly to CMS
· Assure selected Registry or QCDR uses software to electronically aggregate/filter data, calculate measures, & submit to Medicare.
In short, there can be no manual (human) intervention in the process. Reality is that CMS is not necessarily auditing every submission. However, identical to healthcare claim submission in which the medical record must substantiate what was coded and billed, providers attesting to CEHRT End-to-End Electronic Reporting should be prepared to demonstrate they did, in fact, meet the minimum requirements of the bonus opportunity.