Long-term Care Hospital (LTCH) Prospective Payment System Final Rule

On August 2, 2019, the CMS introduced the Long-term Care Hospital (LTCH) Prospective Payment System Final Rule which established highly specific requirements for eligible professionals (EP) from CY 2020. It further advanced the utilization of the Certified Electronic Health Record (CEHRT) based on the requirements of the Medicare and CHIP Reauthorization Act (MACRA), Merit-based Incentive Payment System (MIPS) and Alternative Payment Model (APM).

With the introduction of the LTCH prospective system final rule, came additional criteria. These new requirements center on family health history, patient information management, clinical data importing and quality measures.

As a result of this mandate, eligible hospitals and critical access hospitals (CAH) stand to sustain downward payment adjustments if their EHR systems do not comply with the 2015 CEHRT criteria. From CY 2020, ISVs are required to upgrade their offerings to assure customers of the functionality that would help them conform to the latest meaningful use criteria.

The following are the key takeaways of the LTCH PPS final rule for care providers (EPs and CAHs) with regards to CEHRT.

  • The utilization of the 2015 edition CEHRT is mandatory, beginning from CY 2020.
  • Eligible hospitals must report four eCQMs using certified technology or risk facing negative IQR payment adjustments.
  • Besides using 2015 CEHRT, all eligible hospitals must use the most recent eCQM specifications to capture them.

The 2015 Edition Certified Electronic Health Record Technology (CEHRT)

The 2015 edition certification criteria came to life based on the shortcomings of past rulemakings from the Office of the National Coordinator (ONC). It introduced enhanced certification criteria, bettering the initial requirements laid down by stage 3 of the meaningful use certification requirements. This set the stage for vendors to develop EHR systems that would be capable of being a vital component of an interoperable nationwide health information structure.

In simple words, CEHRT refers to all healthcare IT products that have passed stringent tests on specific criteria mandated by the CMS and the 2015 edition will continue to be a requirement and a standard for EHR systems well into the year 2020.

The following are a list of caregivers who are currently considered as Eligible Clinicians (ECs) and are required to use 2015 CEHRT from the year 2020.

  • Dental surgeons and dental medicine practitioners
  • Clinical nurse specialists
  • Physician assistants
  • Chiropractors
  • Nurse practitioners
  • Podiatric medicine practitioners
  • Optometrists
  • Physicians (including doctors of medicine, doctors of osteopathy, including osteopathic practitioners)
  • Certified Registered Nurse Anaesthetists (CRNAs)

The Precursor

The Medicare Promoting Interoperability Program is central to the Center for Medicare and Medicaid Services’ (CMS) effort in facilitating meaningful use of patient healthcare information. It adopts an elementary approach that involves providing incentives to eligible hospitals that implement certified Electronic Health Record (EHR) technology. Over the past decade, this effort has evolved from meaningful use stage 3 or MU3 to Advancing Care Information (ACI) to Promoting Interoperability (PI). certification criteria. This criterion is to be adhered to by care providers and Independent Software Vendors (ISVs) in the use and development of EHR systems respectively.

Care Providers and Vendors, Take Note!

The reconciliation of clinical information is critical for providers during the measures submission process. From the year 2020, the CMS mandates the receipt of the electronic summary of care records using certified EHR technology.

This puts the onus on all eligible care providers and critical access hospitals to upgrade to 2015 CEHRT or stand to sustain penalties that would directly impact the quality of their care delivery process. Simultaneously, ISVs will be the focal point during the transition period with providers depending on them to conform to the mandates of the final rule.

Talk to your vendors about CEHRT now!


Certification enables care providers to stay confident about their EHR systems and other healthcare IT products. With every improvement in meaningful use criteria, the level of security and interoperability shoots up, moving the healthcare industry closer and closer to the CMS’s vision of patient engagement and meaningful use of healthcare information.

Nalashaa’s iterative certification process has been designed from the ground up to align with the Value-Based Care (VBC) vision of the CMS. We assess, analyze, develop and integrate feature sets that adequately demonstrate compliance to proctors.

We can help you enhance your product for certification and guide you through the entire journey.

For more info on our certification services, reach out to us at info@nalashaa.com

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Puneeth Salian

Puneeth Salian

A writer in Healthcare domain, who is also a science and technology enthusiast. Enjoys creating interesting pieces that elucidate the latest Healthcare IT trends and advancements.
Puneeth Salian

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