Premier Urges Changes to CEHRT Requirements for ACOs

Premier joined more than 100 accountable care organizations (ACOs) and other healthcare organizations in urging CMS to revamp certified electronic health record technology (CEHRT) utilization requirements for ACOs. In a letter to the agency, the groups expressed concern that related policies finalized in last year’s Medicare Physician Fee Schedule will significantly increase burden and jeopardize participation in the Medicare Shared Savings Program (MSSP) and other advanced APMs. Specifically, the groups urged CMS to:

• Repeal two finalized policies: 1) The requirement for all MSSP ACOs, regardless of Qualified Participant (QP) status or track, to report Merit-based Incentive Payment System (MIPS) Promoting Interoperability (PI) data starting with the 2025 performance year; and 2) Updating the CEHRT use criterion for all Advanced APMs from 75 percent to “all” eligible clinicians, also starting in 2025;
• Instead take a two-pronged approach to validate CEHRT adoption and utilization across the ACO and APM community by: (1) instituting a “yes/no” attestation to demonstrate CEHRT adoption and use and compliance with information blocking requirements; and (2) leveraging ONC CEHRT data that are already being collected directly from certified health IT developers; and
• At a minimum, delay both policies until at least the 2027 performance year and establish additional flexibilities, such as a time-limited exception for new ACOs, APM entities, or newly participating practices, as well as applying the MIPS small practice exemption towards the new MSSP PI reporting requirements.