#42 Question [06-13-042-1] What is the relationship between EHR certification and the annual CQM specification updates released by CMS?

ONC and CMS have received many questions related to this topic, which are reflected below. These responses are from both ONC and CMS.

Question 1: When new versions of CQM specifications are released by CMS, do EHR technology developers need to seek retesting/recertification of their certified Complete EHR or certified EHR Module in order to keep its certification valid?

ONC/CMS Response: No. The minimum version required for 2014 Edition certification is the version of CQM specifications released by CMS in December 2012.1 EHR technology that has been issued a certification based on the December 2012 version will remain certified even when CMS releases new versions of CQM specifications.

We strongly encourage EHR technology developers to update to the newest CQMs specifications as they become available since those updates include new codes, logic corrections and clarifications. We also recommend EHR technology developers consider that other CMS programs (beyond the EHR Incentive Programs) and other private sector programs generally update CQMs on an annual basis. As a result, an EHR technology developer’s customers continued ability to successfully participate and report in those other programs could be impacted if the CQM data generated by the EHR technology is based on older specification versions (and no longer accepted by the other programs).

Question 2: As an EHR technology developer, if my EHR technology “Product A” is, for example, already certified to the “December 2012” CQM specifications, can I update it to include CMS’s updated “June 2013” specifications without seeking retesting/recertification? 

ONC/CMS Response: Yes, unless Product A is relabeled. If Product A is relabeled to call it "Product A+2013 CQMs" and an EHR technology developer also wants "Product A+2013 CQMs" listed on the CHPL for its customers to select, the EHR technology developer will need to contact its ONC-ACB and, at a minimum, submit an inherited certified status request to get this new labeled version of Product A issued a certification. Upon receipt of the inherited certified status request an ONC-ACB would have discretion to require additional testing.

Question 3: As an EHR technology developer, if my EHR technology is not yet certified to the CQM certification criteria (45 CFR 170.314(c)(1) through (3)), can my EHR technology be tested and certified to only the newest available version of the CQM specifications or must it be tested and certified to the December 2012 specifications (first or as well) ?

ONC/CMS Response: EHR technology may be presented for testing and certification to only newest CQM specifications. We encourage EHR technology developers to pursue this approach for the program alignment reasons noted in the responses above.

1. See: http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/eCQM_Library.html