How your EHR could become De-Certified under MIPS rule
In a prior post, I identified CMS intent to increase the bar for clinical data sharing. Quite frankly, I missed something important. As I read a bit deeper, the possibility emerges that CMS might, under some circumstances de-certify an installed instance of an EHR. Under MIPS, this would result in the loss of Meaningful Use scores, reduce the options available for CQM submission, and invalidate Advanced APM options. Here's the three-step logic chain leading to that conclusion.
ONC (and by extension, CMS) believes some providers interfere with information exchange - based on an April, 2015 report ONC based on Congressional request. See Page 41, MIPS proposed rule.
CMS requires demonstration that provider did not restrict interoperability: Here's the rub. CMS identifies three specific steps of attestation. You are required to attest that you have implemented technologies, standards, policies, practices and agreements ... etc. So, in the event that you have not addressed Direct Messaging, or some other form of interoperability technology, CMS may have the ability (under the new MIPS rule) to do more than simply disallow this one measure. Page 43, MIPS proposed rule.
Of course, we cannot know CMS's intent. All we can know is what they are enabled to do under this rule, and it is a bit chilling.
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