What is the “Cures Update” and when is it required?
As detailed in the 2020 Interoperability and Information Blocking interim final rule, December 31, 2022 will be last day that the ONC 2015 Edition certification will be valid. After this date, only certified EHR technology (CEHRT) that has achieved 2015 Edition Cures Update certification will be considered certified.
This does not necessarily mean healthcare providers must upgrade or demonstrate use of Cures Update-certified technology by this date. However, they will need to follow the CEHRT rules established by the CMS quality programs in which they participate.
What is the CEHRT deadline for MIPS participants?
In its two most recent Physician Fee Schedules, CMS made clear its intention to maintain the 90-day performance period for the MIPS Promoting Interoperability (PI) performance category. As in the past, providers participating in MIPS PI must demonstrate meaningful use of CEHRT during the entirety of their 90-day performance period in order to receive a Promoting Interoperability score.
Effectively speaking, this gives providers until October 2, 2023 to implement or upgrade to Cures Update-certified EHR technology (i.e., the first day of the last 90-day performance period in 2023).
Providers participating only in MIPS Quality (i.e., not reporting MIPS PI measures) have until the last day of the full MIPS Quality reporting year (i.e., December 31, 2023) to upgrade; however, if also reporting PI, they will need to upgrade by October 2, 2023 at the latest.
What About Advanced Payment Models?
Providers participating in an advanced payment model (e.g., MSSP/ACO, Primary Care First, etc.) requiring use of CEHRT will need to follow the CEHRT rules for their specific program. Here’s where it gets tricky! These programs typically set their CEHRT rules without going through the CMS annual rulemaking process.
So, if you are participating in an APM (or think you might be), it is imperative that you reach out to your contact to determine whether you are required to use CEHRT and, if so, by which date!
Any Other Programs Requiring CEHRT?
You may be wondering whether another program in which you participate, or a payer-based contract requires the use of the Cures Update-certified technology. This is certainly possible; however, such a requirement would be outside the rulemaking process of ONC and CMS. The safest bet is to direct such questions to the sponsoring organization or payer.
Is NextGen Healthcare 2015 Edition Cures Update-certified?
Yes, in March, NextGen Healthcare announced that NextGen® Enterprise EHR version 6.2021.1 achieved 2015 Edition Cures Update certification. Currently, there are two versions listed with this certification on the ONC CHPL website: version 6.2021.1 Patch 79 and 6.2021.1 Cures. Effectively, this means 6.2021.1 with Patch 79 or higher is Cures-certified!
For more information about our 2015 Edition Cures Update Certification, see this FAQ and visit the ONC Certified Health IT Product Listing (CHPL). For more information about the ONC Information Blocking rule, please review 21st Century Cures Act page on Success Community, which includes FAQs, white papers and other useful information.