The 2024 Physician Fee Schedule Final Rule came out last week, with some important updates for rehab therapy.
Notably, the Final Rule has ended automatic reweighting of the MIPS Promoting Interoperability category for rehab therapists, and now requires the use of certified EHR technology for 180 days out of the 2024 performance year.
If you’re using an EMR for PT, OT, or SLP documentation, you may be asking: “What is a certified EHR? Do we have one? What’s the difference between an EMR vs. EHR? Is there time to switch?”
Don’t worry, you’re in the right place to answer those questions. With over a decade of experience in health law, privacy, and compliance, I’ve been closely watching the regulatory changes that have led to this point.
So let’s get you caught up to speed, and explore the history, definition, requirements, and benefits of ONC-certified EHRs.
Timeline of Health IT and Electronic Health Records (EHR) Regulation
For many practices, staying up-to-date with compliance means rolling with the punches year after year, adapting to regulatory updates in real time. But to understand the significance of CEHRT, you have to take a look at the long-term trends in health IT regulation and how they’ve been directly linked to Medicare payments and incentive structures in the U.S.
Follow along with this timeline of health IT and electronic health record regulation—or skip ahead to the next section.
Establishment of the ONC
U.S. President Bush announces a plan to promote the use of computerized health records across the nation’s health care systems. He signs Executive Order 13335 to establish the Office of the National Coordinator for Health Information Technology (ONC) under the U.S. Department of Health and Human Services (HHS).
The Triple Aim
Researchers at the Institute for Healthcare Improvement (IHI) develop a new healthcare framework, called the Triple Aim, alongside 141 participating organizations. The three main goals of the IHI Triple Aim framework are to to improve the quality of care, reduce healthcare costs, and improve population health in the U.S.
The Health Information Technology for Economic and Clinical Health (HITECH) Act is signed into law to promote the adoption of interoperable health information technology and regulate the secure transmission of health information.
ONC issues the Standards and Certification Criteria Final Rule for electronic health record systems. At the same time, CMS finalizes the definition of “meaningful use” of EHR technology, to be implemented in three stages. CMS introduces EHR incentive programs, which require the use of certified EHR systems.
The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) is signed into law. MACRA sets the stage to replace the Sustainable Growth Rate with new quality care reporting and incentive programs, to be launched in 2017. MACRA supports the transition from fee-for-service payment models toward value-based care.
21st Century Cures Act
The 21st Century Cures Act is signed into law to improve patient access to their electronic health information, promote information sharing, and establish anti-information blocking provisions.
QPP, MIPS, and APMs
In line with MACRA, CMS launches the Quality Payment Program (QPP) and introduces two participation pathways: MIPS and APMs.
The Merit-Based Incentive Payment Program (MIPS) requires participants to report activity in four performance categories (Quality, Promoting Interoperability, Improvement Activities, and Cost). The Alternative Payment Model (APM) offers organizations the option of aligning payment structures with specific clinical outcomes or population health goals.
The Medicare EHR Incentive Programs become the Medicare Promoting Interoperability Program.
TEFCA and MVPs
The HHS publishes the Trusted Exchange Framework and Common Agreement (TEFCA) to support the nationwide exchange of electronic health information across health information networks.
CMS MIPS Value Pathways (MVPs) are announced as a new reporting option to fulfill MIPS requirements, including 12 initial pathways.
Updates for Rehab Therapy
In November, the new CMS Physician Fee Schedule Final Rule introduces 5 new MVPs for the 2024 performance year, including “Rehabilitative Support for Musculoskeletal Care.” Additionally, the Rule states that rehabilitation therapy clinicians will no longer be eligible for automatic reweighting of the MIPS Promoting Interoperability category.
What Are the Reasons Behind ONC Certification of EHR Technology?
ONC certification standards are designed to support the goal of widespread adoption of EHRs and health data sharing. Certified EHRs create and transmit data in standardized formats, which can be shared securely between health systems—referred to as interoperability. The certification process requires third-party verification of certain features in the EHR to demonstrate capability of supporting care coordination and interoperability.
What Is the EHR Certification Process?
The 21st Century Cures Act established the latest criteria for EHR certification, called the 2015 HealthIT criteria. HealthIT vendors must satisfy the criteria of the 2015 Edition and pass testing to become certified health record technology (CEHRT). Conducted by third-party assessors, the certification process is voluntary and rigorous.
Certification criteria highlights include:
- Interoperability for electronic patient health data exchange.
- Patient engagement features for accessing health information.
- Care coordination requirements for proper transmission of health data to other providers.
What Are the Benefits of CEHRT for PT, OT, and SLP?
Using certified EHR technology is beneficial to the rehabilitation therapy practice for a number of reasons. Certified EHRs are designed to:
Promote Care Coordination
Certified EHRs can connect with other provider types, such as hospitals and outpatient centers, to coordinate care and improve care quality.
Being connected, or interoperable, saves administrative and provider time by allowing patient health data and eReferrals to flow seamlessly and securely among different health IT systems. Data is stored using a standardized “language,” allowing health information to be used by all providers to deliver evidence-based, quality intervention.
Create a Better Patient Experience
Not only do EHR systems help practices protect patients’ right under HIPAA to access their health records, but they can also benefit patient engagement. With complete records at their fingertips, patients can stay up-to-date and informed of their own health status and treatment goals. Most of all, patients can benefit from more streamlined, safe, and fine-tuned treatment, enabled by interoperability. Accessible + personalized care = better outcomes and happy patients!
Protect Patient Safety
Certified EHRs undergo focused security evaluation as part of the certification process.
CEHRT is designed to make patients’ electronic health record data privately and securely to both patients and their authorized providers. Features that protect the security of patient data include audit trails, data encryption, password protection and access control tools, and more.
Support Medicare Reimbursement
For those who participate in the Quality Payment Program, the use of CEHRT is a requirement of the MIPS Promoting Interoperability performance category. Though rehab therapy has not been required to report in the PI category in the past, the 2024 PFS Final Rule has ended automatic reweighting. Providers not using certified EHR for 180 days out of the performance year will lose valuable points and may face the 9% downward payment adjustment to their Medicare reimbursements in the affected payment year.
Which Is Better for Rehab Therapy: EMR or Certified EHR Technology?
Many EHRs are designed with physician practices and hospitals in mind, which is why some physical therapy, occupational therapy, speech-language pathology and multi-specialty therapy practices have opted for specialized EMRs. But with changes in Medicare regulation, an increasing emphasis on interoperability, and the benefits of using EHRs, many practices are making the switch.
Ultimately, the choice will have to do with the needs of your unique practice. But when you’re making that decision, keep in mind:
Meet Raintree Systems' Certified EHR and Award-Winning Platform
Raintree offers the only certified EHR designed specifically for the outpatient rehabilitation therapy practice setting.
Our unified platform includes award-winning systems for: clinical documentation; patient engagement, digital intake, and payment processing; billing; revenue cycle management; business intelligence, and more.
As a reminder: In order to meet the MIPS Promoting Interoperability requirements in 2024—25% of the total score—you need to demonstrate use of CEHRT for 180 days within the performance year.
If you’re not already using a certified EHR, time is short. Implementing a new system doesn’t happen overnight. Schedule a demo with Raintree, today.
Veda Collmer, JD, CIPP/US, Raintree Systems’ General Counsel, Chief Compliance Officer, brings more than 10 years of experience in health law, privacy and compliance. Veda received the Robert Wood Johnson Foundation Public Health Law Fellowship in 2012 and completed her fellowship at the Arizona State University Sandra Day O’Connor College of Law.