Incorporation of EHR 2015 Version Cures Update for MIPS Reporting 

Since CMS has declared the use of CEHRT for MIPS reporting in the performance year 2023, all EHR vendors must complete their certification within that time.

EHRs have proven to be a convenient way to store and exchange patient data. However, its unique features have increased human trust in it. Now it’s not only a storage medium but a potent MIPS data collection type. So, clinicians participating in MIPS submit their eCQM measures using EHRs. Therefore, like other elements of the MIPS framework, we have certain standards for EHRs. CMS has asked every EHR company to upgrade its software and use a CMS-certified version. Therefore, clinicians have limitations when using the EHR system with the 2015 edition updates for MIPS reporting.

For now, providers have clear instructions from the CMS side to implement CEHRT for MIPS reporting. But the deadlines for implementation were announced recently. In a meeting session with the Deputy National Coordinator of Health Information Technology, September 2023 was finalized as the last date for doing so.

In this blog, we will be discussing this 2015 Cure Update. Alongside this, we will examine how soon healthcare practices with EHRs can implement it. Will they be able to completely update the system as per the certification before the deadline?

EHR Vendors and the Necessity of CEHRT for MIPS Reporting

The 2015 cure updates have been available to us for so long. However, the EHR vendors delayed the certification for some time. As per the Certified Health IT Product List (CHPL) website, only 7 percent of EHRs had completed the certification by September 2022. This means that a larger population of EHR users has not paid attention to it. Thereby, there was not that much strictness at that time.

But for MIPS 2023, CMS has already informed the clinicians about the CEHRT implementation. It has provided flexibility in QPP MIPS reporting in 2021 and 2022. Now, CMS will not accept any excuse. Every EHR vendor must obey the PFS final rule for MIPS reporting in 2023.

What is the 2015 Cures Act?

The 2015 Cures Act, is commonly referred to as the 21st Century Cures Act. It is a federal statute passed by the United States Congress. Also, it was ratified by President Barack Obama in December 2016. There are various provisions in the law. They intend to increase the adoption and functionality of electronic health records (EHRs) in the United States.

  • The 2015 Cures Act includes new certification standards for EHR technology as one of its major updates for EHRs. In essence, it aims to enhance the interoperability of various EHR systems. This will make it simple for MIPS healthcare professionals to transfer patient health data between various platforms. As a consequence, it will enable improved care coordination.
  • The 2015 Cures Act also has provisions regarding patient access to their health records. Additionally, it specifies that EHR systems must grant patients more access. By this provision, patients can now view, download, and transmit their health information electronically.
  • The law also adds additional specifications for EHR vendors. This will serve as proof that modern technology facilitates the adoption of standardized clinical vocabulary. Also, it will aid in enhancing the precision and accuracy of patient health records.

2015 Cures Act Requirements and Compliance Deadlines

The 2015 Cures Act, for sure, gives an outcome-focused format to EHR vendors for MIPS reporting. It serves as the foundation for a developing ecosystem of APIs that will encourage applications for patient access, care coordination, clinical research, public health, and population health management.

Listed below are the compliance deadlines set for fulfilling the 2015 Cures Act requirement.

  • By April 1, 2022, the EHRs must complete all the attestations and certification maintenance.
  • December 15, 2022, is the compliance deadline for the real-world testing plan of 2023.
  • December 31, 2022, has been set as the deadline for:
  • § 170.315(g)(10)—Standardized APIs for Patient and Population Services
    • § 170.315(b)(3) Electronic Prescribing
    • USCDI/Consolidated: Clinical Document Architecture (C-CDA) Companion Guide
    • §170.315(c)(3) Clinical Quality Measures (CQMs)
    • ASTM Updates
    • Attestations of Privacy and Security Transparency
  • By December 31, 2022, EHRs must have completed the privacy and security transparency attestation.
  • Afterward, updates to support security tags will be done until March 15, 2023.
  • At last, there are the final stages of reporting post-annual real-world testing results to ONC-ACB. For this, the deadline is December 31, 2023.

Time is Running Out; Complete Your EHR Certification

As a certified EHR technology, you strive to uphold and satisfy the changing certification requirements. Further MIPS reporting requirements have been released by the QPP for PY 2023. In addition, the new MVP framework for MIPS will be implemented in 2023. Measures for improving interoperability and quality have undergone considerable modifications. Also, MIPS reporting now includes health equity elements. As a result, it’s getting harder to assist your providers as CMS sets higher standards for avoiding fines and securing rewards.

Hurry Up! If you’re one of the 93% of users who aren’t yet 2022-certified. You still need to meet the requirements for 2023, so your task is not easy.


It will take a lot of work on both fronts to support the new 21st Century Cures Act and the changing QPP standards for MIPS reporting. EHR development strategies that contain efficient plans to meet standards will be the most successful. Alternatively, practices must collaborate with solutions to help them achieve one or both of their objectives. With the aid of our MIPS consulting services, you may successfully navigate the value-based care journey and meet QPP criteria. Find out more about how we work with EHR partners to enhance performance and scores for MIPS, as well as how we are