For palliative care organizations evaluating software, ONC certification can feel like an important box to check. And it is. A platform listed on the ONC Certified Health IT Product List, often called the CHPL, demonstrates that the software meets specific federal certification standards for certified health IT. For organizations thinking about interoperability, data exchange, referral relationships, and future value-based care models, that matters.
What ONC CHPL listing, MIPS, and CMS incentives really mean for palliative care teams.
But there is one question that often creates confusion:Does switching to an ONC-certified EMR qualify a palliative care organization for CMS incentive payments?
The answer is: not automatically.
The truth is more nuanced, and it depends on your organization’s billing structure, clinician mix, and whether your clinicians are subject to specific CMS reporting requirements.
At Curantis Solutions, we believe this conversation should be clear from the start. ONC certification is meaningful. It is also not a guaranteed path to CMS incentive payments.
What ONC CHPL Listing Means
The ONC Certified Health IT Product List is the official federal listing of health IT products that have been certified under applicable ONC standards.
When a software platform is listed on the CHPL, it means the product has met specific certification criteria related to certified health IT. This can include capabilities that support interoperability, data exchange, patient access, privacy and security, and other technical requirements.
For palliative care organizations, this can be important for several reasons. Certified technology may help support data exchange with hospitals and health systems. It may be relevant for certain CMS reporting programs. It may also help organizations prepare for future care models that place greater emphasis on interoperability and connected care.
Curantis Solutions is listed on the ONC CHPL. That is a real credential and an important part of our commitment to certified technology.
But CHPL listing alone does not determine whether an organization is eligible for CMS incentive payments.
What ONC Certification Does Not Mean
ONC certification does not automatically make a palliative care organization eligible for CMS incentive payments. Eligibility for CMS programs is based on program rules. Those rules may include provider type, clinician eligibility, billing structure, Medicare Part B volume, reporting status, and other requirements.
This distinction matters because some organizations are told, or assume, that simply switching to an ONC-certified EMR will unlock CMS payments. That is not how the programs work. Certified technology may be required for certain eligible clinicians or organizations to participate successfully in specific CMS programs. But the software itself does not create eligibility where eligibility does not otherwise exist.
The better question is not, “Is the software certified?”
The better question is, “Does our organization or our clinicians participate in a CMS program where certified technology is required or financially relevant?”
What happened to the old EHR incentive payments?
Many people still remember the earlier meaningful use and Medicaid EHR incentive programs. Those programs created incentive payments for certain eligible professionals and organizations using certified EHR technology. Those programs are no longer the same.
The Medicaid Promoting Interoperability Program ended on December 31, 2021. The old Medicare EHR Incentive Program for eligible professionals was sunset and incorporated into MIPS as the Promoting Interoperability performance category.
What remains today is more specific. The Medicare Promoting Interoperability Program continues for eligible hospitals and critical access hospitals. For clinicians, certified EHR technology may be relevant through MIPS, the Merit-based Incentive Payment System.
That is where the conversation becomes important for some palliative care organizations.
Where MIPS May Apply to Palliative Care
MIPS applies to certain clinicians who bill Medicare Part B professional services. For palliative care organizations, this means the first question is whether your clinicians are billing non-hospice palliative care visits under Medicare Part B.
If your organization does not bill Medicare Part B professional services, MIPS may not be financially relevant. If your palliative care clinicians do bill Medicare Part B, the next question is whether they meet the low-volume threshold criteria.
Generally, clinicians are subject to MIPS when they exceed all three low-volume threshold criteria:
- More than $90,000 in Medicare Part B allowed charges
- More than 200 Medicare Part B patients
- More than 200 covered professional services
If a clinician does not exceed all three criteria, they may be excluded from MIPS. If they are excluded from MIPS, there is no MIPS payment adjustment tied to certified EHR technology.
This is why palliative care organizations should be cautious about broad claims. Not every palliative care provider has the same MIPS exposure.
Why Clinician Mix Matters
Even when a palliative care organization bills Medicare Part B, the clinician mix can change the MIPS picture. For example, many palliative care programs are led by nurse practitioners, physician assistants, or other non-physician clinicians. In some cases, the Promoting Interoperability category may be automatically reweighted to 0% for certain clinician types.
That matters because Promoting Interoperability is the MIPS category most directly tied to the use of certified EHR technology.
For physician-led groups that are MIPS-eligible and billing above the low-volume thresholds, certified EHR technology may be required to support the Promoting Interoperability category. For other clinician mixes, the financial relevance may be different.
The takeaway is simple: you need to understand who is billing, how they are billing, and whether they are actually subject to MIPS before estimating the value of certified technology.
The Real Financial Value: Downside Protection, Not a Guaranteed Bonus
One of the most important points to understand is that certified EHR technology should not be framed as a guaranteed bonus. For MIPS-eligible clinicians, the financial value is often better understood as downside protection.
If an eligible clinician is required to report under MIPS and does not successfully participate, they may face a negative Medicare Part B payment adjustment. Certified EHR technology can help support the Promoting Interoperability category, which may be part of the clinician’s overall MIPS score.
That means the value is not necessarily a check coming in from CMS. The value may be helping protect Part B revenue from a potential negative adjustment.
That is a very real benefit. It is just different from the way this topic is sometimes presented.
Why Positive Payment Adjustments Should Be Discussed Carefully
MIPS can include positive, neutral, or negative payment adjustments. But positive adjustments are subject to CMS rules and budget neutrality, which means they are not as simple as saying, “Use certified software and receive a bonus.”
For many organizations, the more accurate and useful way to think about certified technology is this:
- It can help eligible clinicians meet reporting requirements.
- It can help reduce exposure to negative payment adjustments.
- It can support interoperability and data exchange.
- It can prepare the organization for future payment models.
- It should not be positioned as a guaranteed incentive payment.
This distinction protects your organization from making decisions based on incomplete information.
What This Means for Hospice Organizations
Although this article is focused on palliative care, many organizations operate both hospice and palliative care programs, so it is important to clarify the hospice side as well.
Hospice services billed under the Medicare Part A hospice benefit are outside of MIPS. Hospice volume does not create MIPS eligibility.
That means an ONC-certified EMR does not create a direct CMS incentive payment opportunity for hospice agencies based on hospice volume.
For hospice organizations, the value of certified technology is more closely tied to interoperability, data exchange, referral relationships, compliance readiness, and preparation for future value-based care models.
Questions to Ask Before Evaluating CMS Incentive Claims
If you are evaluating software and trying to understand whether ONC certification or MIPS applies to your organization, start with these questions:
- Do our palliative care clinicians bill Medicare Part B professional services?
- Are those services billed independently, or through a hospital or health system?
- Do our clinicians exceed the MIPS low-volume thresholds?
- Are our visit-delivering clinicians primarily physicians, nurse practitioners, physician assistants, or a mix?
- Are we currently participating in MIPS?
- Do we know our current MIPS score or payment adjustment status?
- Has anyone promised us that switching to an ONC-certified EMR will qualify us for CMS incentive payments?
The answers to these questions will give you a much clearer picture of whether certified technology has a direct financial impact for your organization.
Why ONC Certification Still Matters
Even when there is no direct CMS incentive payment, ONC certification can still matter.
For palliative care organizations, certified technology can support interoperability with hospitals, health systems, and referral partners. It can help strengthen data exchange and create a stronger technology foundation for connected care.
It may also support eligible clinicians participating in MIPS, especially physician-led groups billing Medicare Part B above the low-volume thresholds. And as palliative care continues to evolve, certified technology may help organizations prepare for advanced payment models, value-based care arrangements, and future interoperability expectations.
Certification is not the whole story. But it is an important part of a modern, future-ready technology strategy.
The Curantis Perspective
At Curantis Solutions, we believe palliative care organizations deserve clear answers, especially when the rules are complex.
Curantis Solutions is listed on the ONC CHPL. Our palliative care software solution is purpose-built for the realities of end-of-life care, with the modern technology foundation organizations need to support clinical workflows, billing complexity, interoperability, and future readiness. But we will not overstate what ONC certification does.
Using an ONC-certified EMR does not automatically qualify every palliative care organization for CMS incentive payments. Eligibility depends on the organization, the clinicians, the billing structure, and the CMS program requirements that apply. The real value is clarity.
For some organizations, certified technology may help protect eligible Part B revenue from MIPS-related penalties. For others, the value may be interoperability, referral alignment, compliance readiness, and preparation for future care models.
Either way, the right software partner should help you understand what matters, what applies, and what does not.
Want the quick-reference version?
We created a practical FAQ to help palliative care organizations understand ONC certification, MIPS, and CMS incentive claims in plain language.
Ready for a clearer path forward?
Certification matters. Clarity matters more. Curantis gives palliative care organizations both, with certified technology, honest guidance, and a platform purpose-built for the way end-of-life care is delivered.
Book your Curantis Experience and discover how refreshingly simple your software experience can be.