Top Takeaways from 2024 Regulatory Requirement Updates for EHRs

Written by: Kelly Faas, RN, Principal Regulatory Affairs Manager, Veradigm

2024 is a remarkable year for changes in how regulatory bodies monitor electronic health record (EHR) systems. Entire processes and naming conventions are changing alongside a flurry of small tweaks. Here, we'll cover the highlights and what you need to know to ensure your healthcare technology remains compliant.

ONC Certification Name Change

The Office of the National Coordinator for Health Information Technology (ONC) sets rules around EHR systems as part of its certification program. In 2024, it announced it was changing the certification naming convention from yearly editions (e.g., the "2014 Edition") to simply "ONC Certification Criteria for Health IT."

The ONC certification name change not only eliminates the confusion caused by referring to editions but also the risk of sounding outdated. For example, the criteria used in 2023 was called the "2015 Edition" even though it had extensive updates beginning in 2020. Updates to ONC certification align more naturally with how health IT works. The program now has a single set of certifications with an incremental, predictable update cycle that mirrors regular health IT development timelines.

ONC has also updated its definition of a revised certification criterion to mean any criteria with changed or added capabilities. Health IT staff must ensure their systems comply with each revised criterion. In 2024, the revised certified criteria included Decision Support Interventions and standardized Health Level Seven (HL7®) Fast Healthcare Interoperability Resources (FHIR) endpoints.

Merit-based Incentive Payment System (MIPS) Updates

The Merit-based Incentive Payment System (MIPS) is part of the Centers for Medicaid and Medicare Services (CMS) Quality Payment Program (QPP), which is the payment model CMS uses to reimburse clinicians for Medicare services. MIPS provides payment adjustments based on a clinician's performance in four categories: quality, promoting interoperability (PI), improvement activities, and cost. Recent updates to MIPS impact the reporting requirements for several performance evaluation categories.

2024 MIPS Promoting Interoperability Requirement Updates

For 2024 reporting, CMS requires health IT services to use EHRs that meet 45 CFR 170.315 for reporting in the MIPS PI category. The reporting period for MIPS PI has also increased from 90 to 180 days minimum. It will continue to increase in the coming years, eventually reaching a full year. This is a key update because health IT departments must start gathering PI data as soon as possible to have roughly six months of data by the end of the year.

Certain types of clinicians and special status designations can result in automatic reweighting for MIPS PI. Automatic reweighting means that qualifying groups are exempt from reporting PI. In 2024, clinical social workers and ambulatory surgical center (ASC)-based, hospital-based, non-patient-facing, and small practice groups and entities will be exempt from reporting PI data.

Another MIPS PI update concerns the querying of Prescription Drug Monitoring Programs (PDMPs), electronic databases for tracking controlled substance prescriptions. The ONC has removed exclusion three from the measure. Exclusion three allowed clinicians to skip the measure if querying a PMDP imposed "an excessive workflow or cost burden."

Finally, clinicians must include their EHR's CMS identification code from the Certified Health IT Product List (CHPL) and attest to not limiting EHR compatibility, complying with ONC direct review, and taking the appropriate steps toward a safe and compliant EHR. Figure 1 lists key updates to MIPS PI.

2024 MIPS Quality Requirement Updates

Clinicians must report performance data for at least 75% of denominator-eligible cases for 2024. Denominator-eligible cases are all patients eligible for a certain treatment, whereas numerator-eligible cases are all eligible patients who receive treatment. Health IT staff use these numbers to calculate the percentage of eligible patients who receive treatment. Achieving 75% should not be a problem for most practices reporting directly out of EHRs, where 100% of cases will be reported.

To ensure quality patient care, clinicians must submit collected data for at least six clinical quality measures (CQMs). CQMs may be collected electronically (eCQMs) using data from EHRs. Table 1 shows CMS updates to eCQMs in 2024.

Table 1. eCQM Changes in 2024

In addition to eCQM changes, registered groups, virtual groups, and Alternative Payment Model (APM) entities must contract with a Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS Survey vendor for Spanish translations in 2024. Individual MIPS-eligible clinicians may earn up to ten additional percentage points for improved scores in quality performance categories from previous years.

MIPS Changing to MVP in Future Years

CMS currently offers three reporting options: traditional MIPS, APM Performance Pathway (APP), and MIPS Value Pathways (MVPs). The APM APP pathway is for MIPS clinicians who work with a specific clinical condition, care episode, or population. The MVPs option is currently not required. However, in the future, CMS will retire MIPS and make MVPs mandatory (Figure 2).

Figure 2. Transition Timeline from MIPS to MVPs (Sourced from CMS QPP website)

MVPs are directly related to a specialty or goal. Each MVP has a unique grouping of eCQMs to reward clinicians for providing high-quality care or help clinicians improve the value of care they provide. There are sixteen MVPs, including advancing cancer care, promoting wellness, optimizing chronic disease management, and more.

High Priority Practices SAFER Guide Now Mandatory

For 2024 reporting, the ONC will require the High Priority Practices Safety Assurance Factors for EHR Resilience (SAFER) self-assessment. This downloadable form helps health IT professionals prepare for audits by identifying and mitigating EHR risks. Examples of recommended practices include data backup, patient identification throughout the workflow, and interactive clinical decision support features. The SAFER guide includes a worksheet with room for notes, follow-up actions, assigning staff to follow-up actions, and specific examples of useful practices.

FQHCs Values Updates for 2024

Federally Qualified Healthcare Centers (FQHCs) are outpatient clinics in rural areas that qualify for CMS reimbursement. Recent updates to FQHCs' EHR compliance require incorporating additional box values for patient demographics. Examples include true/false values for veteran and homeless status and additional sexual orientation and ethnicity values. Veradigm recommends reviewing provider and insurance mappings once 2024 reports arrive to ensure all providers are listed and note information that must be changed. FQHC health IT can work with Veradigm support to update values and view reports.

Stay Ahead of Changes with Veradigm EHR

The Veradigm EHR team is working to make compliance with ONC certification as simple as possible for our clients. Keeping our clients informed about what is happening is critical since the certification has switched from occasional overhauls to incremental, continuous changes.

To meet 2024 reporting requirements, clients must use Veradigm EHR version 23.4 at minimum. Veradigm EHR is registered with CHPL and has a CMS code clients can use when reporting for MIPS PI. Also, Veradigm's nationwide interoperability framework, Carequality, meets the requirements to align with the Trusted Exchange Framework Care Agreement (TEFCA).

Veradigm also provides tools on the client portal to help clients navigate eCQM documentation. The workflows and worksheets guide clients toward what to document, CMS-approved codes, and requirements for meeting numerators. Tools identify all the information needed to generate reports so clients can ensure they are meeting MIPS requirements.

Learn how Veradigm EHR can help busy practices succeed amid regulatory changes.

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