The Quality Payment Program (QPP) has a requirement for Electronic Health Record (EHR) or other Health Information Technology (IT) Vendors to obtain the appropriate submitter role in QPP for each Tax Identification Number (TIN) (group or individual clinician) on whose behalf they will be reporting. The Centers for Medicare & Medicaid Services (CMS) has received feedback that this requirement is burdensome for EHR and Health IT Vendors who submit data to QPP on behalf of large numbers of eligible clinicians or groups. This requirement also can be burdensome for their customers. In most cases, the EHR or Health IT Vendor does not have the required role in QPP and obtaining the role may be too time consuming to complete during the data submission period.
CMS is offering an alternative solution for EHR and Health IT Vendors. This solution will allow you to log into the QPP website, and upload submission data in QPP JSON or Quality Reporting Document Architecture Category 3 (QRDA 3) formatted files on behalf of your clinicians and/or groups without having to obtain a submitter role for each clinician and group.
In order to take advantage of this solution, your organization must be an EHR or Health IT Vendor that:
- Will be submitting on behalf of multiple clinicians and/or groups;
- Is not a 2019 Qualified Registry or QCDR; and
- Is unable to procure submitter roles for all of the eligible clinicians or groups on whose behalf you will report to QPP.
To take advantage of this solution, the contact listed for your organization here must email the QPP Help Desk at firstname.lastname@example.org before COB on Thursday, December 20th, 2019. The email must include the following information:
- Subject line: 2019 EHR Burden Reduction Program Request
- Contact Name
- Contact Title
- Organization Name
- Work email address
- Work phone number
Once you have contacted CMS with all of the information above, we will reply with next steps. We appreciate the feedback we have received and look forward to working with our EHR and Health IT Vendor partners to facilitate provider participation in QPP.