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EHR Systems and MIPS: What Certified EHR Technology Means for Reimbursement
Most practices assume that if their EHR system can generate reports and export data, it satisfies whatever federal reporting requirements come with using electronic records. That assumption is wrong often enough to matter, and the gap between “has an EHR” and “has a certified EHR” is exactly where a chunk of MIPS score, and Medicare payment, can quietly disappear.
This isn’t the EMR versus EHR terminology question, which we’ve covered elsewhere. This is about something more specific: whether the EHR system a clinician is using actually meets the federal certification standard required for MIPS reporting, and what happens if it doesn’t.
What Makes an EHR "Certified"?
Certified Electronic Health Record Technology, or CEHRT, refers to EHR software that has passed testing through the ONC Health IT Certification Program. That testing confirms the software meets specific technical standards for capturing, storing, and securely exchanging patient data. Under the current HTI-1 Final Rule, ONC no longer certifies technology in year-based “editions.” Instead, certification follows a single, continuously updated set of criteria found at 45 CFR 170.315.
This matters because plenty of software marketed as an “EHR system” was never put through this certification process, or holds certification for criteria that have since been updated. A system can look and function like a modern EHR without meeting the specific certification standard a federal program requires.
Why Certification Matters for MIPS
Clinicians participating in the Quality Payment Program through the Merit-based Incentive Payment System, or MIPS, are scored across several performance categories. One of those, Promoting Interoperability, specifically requires the use of ONC-certified health IT to collect and report data. This category has historically represented a significant share of the overall MIPS Final Score.
To meet this requirement, the certified technology generally needs to be in place before the clinician’s chosen performance period begins, and the certification itself needs to be current by the end of that period. A clinician using software that was certified under an older set of criteria, or that was never certified at all, can find themselves unable to properly report the Promoting Interoperability category, regardless of how capable the software otherwise is.
How to Check If an EHR Is Actually Certified
The most reliable way to confirm certification status is to search the Certified Health IT Product List, maintained by ONC, rather than relying on a vendor’s marketing claims. A vendor’s website calling a product “certified” isn’t the same as that specific product, and the specific version and modules in use, actually appearing on the current list with the right certification criteria.
Practices switching EHR vendors, or evaluating a new system, should confirm certification status directly against this list before assuming a system will support MIPS reporting.
What Happens If an EHR Isn't Properly Certified
This is the part that gets left out of most general EHR content. If a clinician’s EHR system isn’t certified, or if certification requirements aren’t met for the full performance period, the Promoting Interoperability category typically cannot be properly reported. Since this category makes up a meaningful portion of the overall MIPS score, an uncertified or improperly certified system can directly reduce a clinician’s final score, which in turn affects the Medicare payment adjustment tied to MIPS performance.
In practical terms, a practice can be documenting excellent care and still lose ground on its MIPS score for a reason that has nothing to do with the quality of care and everything to do with whether the underlying software cleared a specific federal certification bar.
Certification Isn't the Only Requirement
Even with certified technology in place, clinicians reporting the Promoting Interoperability category also need to complete several required attestations, including a security risk analysis and an attestation confirming they haven’t knowingly limited the interoperability of their certified technology. Certification is a necessary foundation, but it doesn’t automatically satisfy every requirement in the category on its own.
What This Means for Practices Evaluating an EHR System
When comparing EHR systems, certification status deserves the same weight as clinical usability and cost, particularly for any practice participating in MIPS. Questions worth asking a vendor directly include which specific certification edition or criteria their product currently holds, whether that certification is current for the performance year in question, and how the vendor handles recertification when ONC updates its criteria.
None of this replaces having a strong Quality Payment Program reporting process. But it does mean the EHR system itself is one of the first things worth verifying, not something to assume is handled simply because the software is modern and full-featured.
What does it mean for an EHR system to be certified?
It means the software has passed testing through the ONC Health IT Certification Program, confirming it meets specific technical standards for capturing, storing, and securely exchanging patient data, currently defined under 45 CFR 170.315.
Is every EHR system automatically MIPS-compliant?
No. Only EHR technology that holds current ONC certification satisfies the requirement for the MIPS Promoting Interoperability performance category. A system can function well clinically without holding the specific certification MIPS requires.
How do I check if my EHR is certified?
The most reliable method is searching the Certified Health IT Product List (CHPL), maintained by ONC, rather than relying on a vendor's marketing claims about certification.
What happens if my EHR isn't certified and I report MIPS?
The Promoting Interoperability category generally cannot be properly reported without certified technology in place for the required performance period, which can reduce your overall MIPS Final Score and affect your Medicare payment adjustment.
Is certification the only requirement for the Promoting Interoperability category?
No. Clinicians also need to complete required attestations, including a security risk analysis and an attestation about not limiting the interoperability of their certified technology, in addition to using certified software.
What's the difference between this and the EMR/EHR terminology question?
That's a separate topic covered in our EMR systems article. This piece focuses specifically on certification status and its effect on MIPS reporting and Medicare payment, regardless of whether a system is labeled EMR or EHR.
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Verifying EHR certification status is one part of staying on top of MIPS reporting requirements. If your practice needs support navigating Promoting Interoperability measures, attestations, and the broader Quality Payment Program reporting process, [Mediflows' Quality Payment Program support] can help confirm your practice is set up correctly before a performance period closes.
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