[Checklist]: CMS’s New CEHRT Requirements for ACOs

If you’re an ACO, your Promoting Interoperability (PI) requirements under CMS’s Quality Payment Program (QPP) are about to get harder.

The primary culprit? An updated requirement that dictates that, in 2025, 100% of your ACO’s participants must operate on a Certified Electronic Health Record Technology (CEHRT). The 2025 mandate will apply to all ACOs, regardless of whether you’re a MIPS APM or an advanced APM. (If you are unclear on what a CEHRT is, read CMS’s definition here.)

How the 2025 CEHRT requirements will impact you

The 100% CEHRT-compliance mandate is a major leap from CMS’s 2024 requirements, when only 50% of MIPS APM participants and 75% of advanced APM participants needed to be on CEHRT. Up until now, you likely had enough responsible participants to hit those marks without much oversight.

Now, with the 2025 update, just one bad apple could spoil the whole PI bunch. Therefore, it will be up to you, at the centralized ACO level, to oversee this requirement moving forward in order to ensure that every single participant is meeting the mark, even if your participants submit their PI requirements at the individual or group level.

The light at the end of the CEHRT requirements tunnel

Before you start panic-breathing into a paper bag, here are two pieces of good news:

1. Like all requirements in the PI category, the 100% CEHRT requirement is bound to a 180-day reporting period. That means you have until July 1st, 2025, to initiate your reporting period — giving you more than half a year to get ready if you start now.
2. Medisolv has created a shareable template — The Medisolv CEHRT Compliance Checklist for ACOs — that you can use to inventory each and every one of your participants to get a baseline understanding of where you stand now as you prepare for 2025.

We’ll talk more about how to plan for 2025 in just a moment. But first, let’s get a better understanding of why this requirement is happening now — and what can happen if you choose to ignore it.

Why is CMS mandating 100% CEHRT compliance now?

It’s all part of CMS’s push to make Electronic Clinical Quality Measures (eCQMs) and Digital Quality Measures (dQMs) the future of quality measurement.

In order to be certified as a CEHRT by CMS, an EHR must be capable of generating a QRDA 1 file. QRDA 1 files are the technological linchpins that allow EHR data to get transformed into meaningful eCQM results. So, CERHTs give us QRDA 1 files, and QRDA 1 files give us eCQMs. It’s one big happy family.

Are there any exceptions to the CEHRT requirement?

There are a few exceptions to the CEHRT requirement. However, these only apply at the individual NPI or group TIN level. Individuals or groups may be excluded from your ACO’s final CEHRT tally if they...

• Do not meet the low-volume threshold (<= $90,000 in annual Medicare billings or <= 200 Medicare Part B patients or covered services)
• Are not a MIPS eligible clinician
• Qualify for a PI category reweighting to 0%

In general, your ACO itself cannot qualify for any PI exceptions. The only exception (pun intended) to this rule is the small practice exception, which your ACO may qualify for provided that 100% of your practices meet the small practice requirements.

How will CMS verify 100% CEHRT compliance?

It’s not an exact science just yet. CMS will likely, as part of their evaluation of the annual scoring and performance, look for a matchup between eligible participants in your ACO and those participants’ PI submissions.

Keep in mind that CMS always has the option to audit your participating providers to make sure everyone’s using CEHRT. Considering the fact that it’s turning up the heat on CEHRT compliance, we wouldn’t be surprised if they also ramp up the randomized audits. In other words, don’t try to cut corners on this issue.

What happens if we fail to meet the CEHRT requirement?

CMS has not announced what will happen for noncompliance, only that “remedial action” could be taken. This could include a denial of incentive payments, a termination of the ACO participant agreement, and an official monitoring plan.

Tips for achieving 100% CEHRT compliance in 2025

Tip 1: Commit to climbing the mountain

Start by making sure you, your quality management team, and your ACO leadership adapt the right mindset. As we indicated above, CEHRT compliance is just a stepping stone towards a long list of future eCQM requirements. Applying band-aids now will only cause you more pain later. Commit to doing the whole CEHRT process across your entire ACO now and doing it correctly.

Tip 2: Determine how you will handle PI submissions

You are allowed to submit your CERHT requirement (and all your PI requirements) one of two ways:

• At the aggregate APM level, on behalf of 100% of your eligible clinicians
• Or 100% of your eligible clinicians must submit as an individual or as part of a group submission

We recommend making the call for all your participants now in order to minimize confusion during the planning and execution of this requirement. Either way you choose to go, you will need to provide oversight of the process.

Tip 3: Map out your milestones

Start with your deadline for 100% compliance – July 1st, 2025 – and work backwards. Key steps you need to consider are:

• Assessing your ACO’s current CEHRT status (see tip #4)
• Converting non-CEHRT practices to CEHRT — this could include practices that are still operating on paper!
• Verifying and documenting each participant’s CEHRT status ahead of your APM submission OR requesting proof of PI submission if you choose to go the individual/group submission route

Tip 4: Inventory every TIN

You need to understand the EHR status of every single TIN. To do that, you can use our handy template. Or, if you prefer to take the DIY approach, make sure, at a minimum, you’re gathering the following info from each TIN. Keep in mind that a TIN may be operating on multiple EHRs, so you’ll want them to submit this info on each EHR in their system:

• Name of EHR
• Software version
• Is it CEHRT?
• Can it generate a QRDA 1 file?
• Can it meet all other PI requirements, such as e-prescribing?
• Which eCQMs (if any) are currently live in the system?
• Do you have any plans to switch EHRs in the next 12 months?
• Do you have any practices still operating on paper?

Tip 5: Update your requirements for future members

To make sure you don’t have to repeat this process again as your ACO grows, consider formally updating your requirements for future members who wish to join your system. CEHRT compliance, the ability to generate QRDA 1 files, and the ability to successfully report on the PI category should be minimum standards of entry into your ACO moving forward.

Tip 6: Begin testing QRDA capabilities now

For the ACOs we’ve been working with here at Medisolv, this has been a big hurdle. Each group within an ACO tends to be at a different phase in their journey to being QRDA 1-capable. What’s more, some EHRs are more difficult than others when it comes to wrangling a usable QRDA 1 file. You can make your life much easier in the long run if you work with each practice now to finalize their QRDA 1 capabilities as you verify their CEHRT compliance.

Still feeling unCEHRTain? Help is here.

Medisolv can help your ACO take control of its QPP requirements with solutions like our APP Reporting Package designed exclusively for ACOs, and unlimited 1-on-1 support from our Clinical Quality Advisors. Schedule a time to get to know us today, or check out these other helpful tools from our Education Center:

• Article: What is a Medicare CQM?
• Guide: 2025 QPP: Proposed Changes from the PFS Proposed Rule
• Webinar: 2025 PFS Proposed Rule – What’s Changed?