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Electronic Health Record (EHR) Questions

Demonstrating proficiency in EHR is a prerequisite to medical licensure in Massachusetts


M.G.L. c. 112, § 2 requires that physicians applying for initial medical licenses and those seeking to renew or revive their licenses must demonstrate that they are proficient in the use of electronic health records (EHR). Demonstrating proficiency in EHR is now a prerequisite to medical licensure in Massachusetts.


Q: When does a physician need to demonstrate proficiency in EHR?

A: Physicians who are renewing their licenses on April 1, 2015 and after will need to demonstrate EHR proficiency.


Q: How many times does a physician need to demonstrate proficiency in EHR?

A: A physician only needs to demonstrate proficiency once.


Q: How does a physician “demonstrate proficiency” with electronic health records?

A: Applicants, Renewing Licensees and Lapsed Licensees must demonstrate proficiency in the use of EHR in one of the following ways:

  1. Participation in a Meaningful Use program as an eligible professional; OR
  2. Employment with, credentialed to provide patient care at, or in a contractual agreement with an eligible hospital or critical care access hospital with a CMS certified meaningful use program;
  3. Participation as either a Participant or Authorized User in the Massachusetts Health Information Highway, “Mass HIway” OR
  4. Completion of three hours of a Category 1 EHR-related Continuing Professional Development (CPD) course that discusses, at a minimum, the Core and Menu Objectives and the Clinical Quality Measures for Meaningful Use. The three EHR credits may be used toward the required 10 risk management CPD credits.


Q: Are any physicians exempt from the EHR Requirement?

A: Yes, beginning on April 1, 2015, the following applicants and licensees may certify on their license applications that they are exempt from the EHR requirement:

  • Physicians who are not engaged in the practice of medicine
  • An Administrative Licensee; Demonstrating Proficiency in EHR FAQs – Rev. 03/15
  • A Volunteer Licensee
  • An applicant for any license who is on active duty as a member of the National Guard or of a uniformed service called into service during a national emergency or crisis
  • An Emergency Restricted Licensee
  • An Inactive Licensee

Exemptions must be claimed each renewal cycle, if applicable.


Q: Will physicians be able to ask for a waiver of the EHR Requirement?

A: Yes, beginning on April 1, 2015, a renewing licensee who is experiencing “undue hardship” in meeting the requirement may ask the Board for a waiver of the EHR requirement.

A waiver extends the time for you to demonstrate EHR proficiency. The Board may, in its discretion, grant a 90-day waiver of the EHR Proficiency requirement, during which time the Board may extend the validity of the license. Board Policy 15-03 describes the process for applying for a waiver. See EHR Waiver Policy.


Q: Are there CPD courses available online that will satisfy the EHR licensing requirement?

A: Yes, there are online CPD courses available.


Q: Does a physician have to own an EHR system in order to be licensed in Massachusetts?


A: No, a physician does not have to own an EHR system to qualify for medical licensure in Massachusetts.  A physician must “demonstrate proficiency” with EHR.

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