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EHR Deadlines in 2023: What You Need to Know

CMS HHS EHR reporting Quality Promoting Interoperability 2023

With the 2022 holiday season in full swing, we thought it would be a good idea to remind everyone of the important deadlines coming up next year for MIPS reporters. 2023 will be here before you know it! 

In this blog, we'll review what you need to know about the changing EHR certification requirements, what parts of your MIPS reporting these changes will impact, and the important deadlines you need to know.

What is the New Requirement?

For the 2023 performance year, MIPS reporters must use 2015 Edition Cures Update certified EHR technology. This update will allow electronic health information to be more easily shared between certified health IT systems and by patients themselves.

When are the Important Deadlines?

  • December 31, 2022: EHRs must meet the conditions of the 2015 Edition Cures Update to keep their certification. This deadline is only really relevant to EHR vendors, since practices aren't responsible for building this functionality within their EHRs. We have heard from our clients that some EHR vendors have already begun letting their customers know that the update is available.

  • For Practices:
    • You must have the functionality of the 2015 Edition Cures Update by the first day of your Promoting Interoperability 90-day performance period in 2023.

    • Your EHR must be certified to the 2015 Edition Cures Update by the last day of your Promoting Interoperability 90-day performance period in 2023.

    • For those reporting via eCQM in the Quality category, your EHR must be certified to the 2015 Edition Cures Update by the last day of your reporting period. 

Next Steps

  • Check with your EHR vendor to find out when the 2015 Edition Cures Update will be available to you, and make sure it happens in time for the important deadlines above. 
  • Check out our 2023 Top MIPS Final Changes Report for a quick rundown of major MIPS changes relevant to our specialties.
  • Subscribe to our blog via the popup on the blog pages to get alerts on this and other important issues.
  • You can also subscribe to our newsletter using the field in our website footer below.

If you want hands-on, personalized assistance, contact us and we will have your back. 


Juliette Walle

Written by Juliette Walle

Juliette Walle is a Health Policy Analyst at the consulting firm MarsdenAdvisors.

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