Making the CEHRT Switch: EHR Upgrade Required for Incentive Payment Programs
By Sean Price Texas Medicine January 2019


In medicine, a lot of things can be stressful. Done right, the switch to the latest certified electronic health record technology (CEHRT) doesn’t have to be one of them.

The change is inevitable in the coming year for physicians already using EHRs to participate in Medicare or Medicaid incentive payment programs. Most practices are using the 2014 version. Beginning in 2019, physicians must use 2015 CEHRT for the 2019 performance period, which ultimately determines their payment.

The rollout is still in early phases, and the Texas Medical Association is on alert for any concerns that arise, which is not uncommon with EHR upgrades. But unlike past changes, physicians are hopeful this one actually could bring some practice improvements.

There will be some physician training required, but most EHR vendors are likely to make the transition as effortless as possible, says Ogechika Alozie, MD, vice chair of TMA’s Ad Hoc Committee on Health Information Technology. (See “Your EHR Upgrade Checklist,” page 42.) 


“That’s how [this] should work for most people,” said the El Paso infectious disease specialist, who prepared for the switch in November. 

And the sooner the better, says Austin family physician Eric Weidmann, MD, a former member of TMA’s Council on Practice Management and chief medical officer at an EHR software company. At the very latest, physicians have until Oct. 1, 2019, but he warns against waiting that long. 

“You could just switch it on [on October 1] and go and take whatever metrics you got. But [if] you’re trying to do process improvement and practice improvement, you need some time to analyze and assess your workflow,” he said.

Physicians also might need time to find the right vendor to stay compliant. TMA experts recommend you start the conversation with your vendor now to understand their future plans. 

Another EHR requirement

The 2015 CEHRT is required for participation in Medicaid Meaningful Use and the Promoting Interoperability performance category of Medicare’s Merit-Based Incentive Payment System (MIPS). 

Promoting Interoperability (formerly Meaningful Use and then Advancing Care Information) is one of four MIPS performance categories that affect a physician’s future Medicare payments, along with quality, cost, and improvement activities. Each category is individually weighted to determine physicians’ total quality score — and ultimately payment — in MIPS. 

Physicians reporting their quality data or improvement activities through some means other than an EHR, such as a qualified clinical data registry (QCDR), are not affected by this upgrade. However, 2015 CEHRT is required for those participating in Medicare’s other quality payment track, alternative payment models (APMs), under the Medicare Access and CHIP Reauthorization Act of 2015 (

Physicians using their EHR to report for all performance categories need the 2015 CEHRT for the full year as the quality category requires full calendar-year reporting. At minimum, the promoting interoperability and improvement activities categories require a continuous 90-day reporting period. So physicians theoretically could upgrade in time to start using it by Oct. 1, 2019 — about 90 days before year’s end. 

However, Dr. Weidmann says June 1, 2019, is a safer deadline, and Sept. 1, 2019, is probably the latest any practice should wait to leave time to test and adjust for the change.

Practice improvements, challenges

The 2015 CEHRT upgrade could help physicians improve practice operations by allowing them to do more with their EHR. For instance, in response to some of medicine’s concerns, the upgrade could help physicians more easily access and share patient data and could improve patient engagement by allowing patients to access their data through a mobile application. (See “Key 2015 CEHRT Updates,” right.)


With these and the other new features, physicians should see improvements in patient care, better use of data, and improved interoperability, Dr. Weidmann says. 

“That’s big stuff,” he said.

And most practices will get those benefits without disrupting practice operations, he says.

“Almost all of the folks doing this will not have a major shift or change,” he said. “It will just be a version update. You’ll see a couple of new icons and things will look a little different, that type of thing.”

The upgrade should not come at additional cost to most physicians through their EHR vendors — something TMA has continuously advocated for — although some vendors may charge for it. TMA continues to urge the Centers for Medicare & Medicaid Services to provide a MIPS exemption for physicians with significant hardships upgrading to 2015 CEHRT.

Some physicians — usually those with small or more specialized EHR vendors — could find the changeover more challenging, Dr. Alozie says. These are mostly companies tailored to subspecialty practices whose vendors have not kept up with EHR rules spelled out by the Office of the National Coordinator for Health Information Technology.

“Some people do find their systems cannot deliver a compliant version, and they do have to do major system change,” Dr. Weidmann added. And far from being a minor lifestyle change “that is akin to getting a divorce and moving to a different city.”

This kind of transition can be especially difficult for small practices because they can’t easily spare physicians or staff to train on the new software, says Joanne Van Winkle, office manager for Medina Valley Family Practice in Castroville. 

“Not every clinic has the luxury of having a staff member who is very versed in this stuff,” she said. 

Vendor vigilance

Even if the changes physicians face are relatively minor, Dr. Weidmann says most will need training, practice, and time to learn the new software. 

“It takes a few hours of working through learning the basics, and then to deploy, then another hour a few weeks later to test to make sure you’ve got it right,” he said. “It’s not just that I can take a weekend, throw it down, and make it happen. It’s an interactive process of interoperability between the provider, other providers, and patients.”

In many cases, physicians will simply have to relearn where certain pieces of information, like dates and types of medicine, go into the new electronic formats. Other changes might be harder to get used to, such as using a mobile version of the portal system that communicates with patients for the first time. 

For those practices that struggle with the switchover to the 2015 CEHRT, the experience should be a wake-up call, Dr. Alozie says. It is worth spending a little extra to get the right vendor who is going to keep your practice current. (See “TMA Can Help” page 41.) 

“If you choose an EHR vendor who doesn’t keep up with these changes and doesn’t do it automatically for you on the backend, you’re inviting a world of hurt onto yourself,” he said. “You have to find a vendor that fits your needs, that takes on the responsibility — and owns it — of [helping you adapt to] changes in health care. Because those changes are not going to stop.”

TMA Can Help

TMA’s practice management consultants can provide customized on-site assistance to help with your electronic health record implementation or transition. They also can help guide you through successful reporting on Medicare’s Merit-Based Incentive Payment System and educate staff on the purpose, process, and potential outcomes of taking part in the quality reporting system. TMA Practice Consulting provides services to TMA members at below-market rates. For more information, contact TMA Practice Consulting at (800) 523-8776 or


Tex Med. 2019;115(1):40-42
January 2019 Texas Medicine Contents
Texas Medicine Main Page

Last Updated On

February 27, 2019

Originally Published On

December 21, 2018

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Sean Price


(512) 370-1392

Sean Price is a reporter for Texas Medicine and Texas Medicine Today. He grew up in Fort Worth and graduated from the University of Texas at Austin. He's worked as an award-winning writer and editor for a variety of national magazine, book, and website publishers in New York and Washington. He's also helped produce Texas-based marketing campaigns designed to promote public health. Sean lives in Austin and enjoys hiking, photography, and spending time with his wife and two sons.

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