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Demystifying MIPS Promoting Interoperability Measures 

by | Aug 11, 2023

The Medicare Access and CHIP Reauthorization Act (MACRA) was enacted in 2015 to reform the Medicare payment system and shift the focus from volume-based reimbursement to value-based care. It replaced the Sustainable Growth Rate (SGR) formula, which had been used to calculate Medicare payment updates for healthcare providers. 

Under MACRA, the Merit-based Incentive Payment System (MIPS) was established as one of the payment tracks for eligible clinicians. MIPS consolidates several existing quality reporting programs, including the Physician Quality Reporting System (PQRS), the Value-Based Payment Modifier (VM), and the Medicare Electronic Health Record (EHR) Incentive Program for Eligible Professionals (Meaningful Use). 

Understanding MIPS Interoperability Measures 

“MIPS PI” typically stands for “Promoting Interoperability” (PI) category and replaces the Medicare EHR Incentive Program (Meaningful Use). MIPS PI carries a weight of 25% of the total MIPS score. The MIPS PI measure focuses on the meaningful use of CEHRT (Certified Electronic Health Record Technology), promoting patient engagement, and exchanging health information between providers. 

Why are MIPS Promoting Interoperability Objectives Important? 

The promoting interoperability performance objectives in the MIPS program provide a framework for exchanging health information seamlessly, enabling care coordination, improving patient outcomes, streamlining data management, and enhancing efficiency across healthcare institutions. By fully embracing the following objectives, healthcare providers can improve clinical decision-making, leading to better outcomes for patients. 

1.) Improved Healthcare Coordination and Information Sharing 

The electronic case promoting interoperability program makes it possible for different healthcare systems to communicate, share, and access patient health information from one system to another. This capability allows for effective and timely patient care across different healthcare settings, reducing the risk of medical errors, and improving the overall quality of care. 

2.) Improved Patient Outcomes 

Interoperability functionality measures help streamline healthcare operations by facilitating the secure exchange of patient data between systems. This capability enables different physicians to review and assess medical history, current medications, lab results, and other vital health information. As a result, eligible clinicians can make well-informed clinical decisions, leading to improved patient outcomes. 

3.) Reduced Administrative Burdens 

Sharing health information seamlessly between systems simplifies tasks such as patient intake and scheduling, freeing up front office staff to focus on essential functions. Providers can also process claims more efficiently and accurately, reducing the likelihood of claim rejections and denials. 

4.) Eligibility for Incentive Payments 

Since promoting interoperability measures in 2017, healthcare providers have been required to meet specific data sharing conditions to earn full points under the MIPS scoring system. Providers who meet these measures can significantly increase their revenue by earning incentive payments from the Centers for Medicare and Medicaid Services (CMS). 

How MIPS Promoting Interoperability Scoring Works 

The PI scoring focuses on the advancement of health information exchange and the use of certified healthcare technology to enhance patient engagement and improve the quality of care. The total PI score has a weight of 25% in the MIPS scorecard. 

 There are four performance categories within the MIPS Promoting Interoperability scoring: 

  •  e-Prescribing – Providers use electronic prescribing technology to prescribe medications. 
  • Health Information Exchange (HIE) – Providers share patient health information using HIE technology allowing for seamless interoperation between different healthcare providers. 
  • Provider-to-Patient Exchange (PPE) – Providers communicate relevant health data with patients via electronic means such as email or EHR patient portals. 
  • Public Health and Clinical Data Exchange – Providers submit patient data to public health agencies for reporting requirements. 

How to Achieve a High PI Score 

To achieve a high PI score, providers must complete certain required measures and may also choose additional objectives to earn extra points. The requirements are divided into base score objectives and performance score objectives. The base score objectives are mandatory, while providers can choose elective performance score objectives to achieve a higher score.  

Another way to achieve a high PI score is by opting for the PI bonus score. Providers can earn a bonus score by participating in any of the following activities:  

  • Submitting relevant clinical data to a public health agency 
  • Completing more than one PI performance category 
  • Submitting data using the 2015 Edition of certified EHR technology 
  • Completing the Improvement Activity category 

By staying informed and keeping up with the latest requirements, providers can leverage this program to improve their practice and benefit their patients. 

MIPS PI Hardship Exceptions 

Eligible hospitals and healthcare professionals who experience hardship or difficulty with meeting the PI category requirements may be given a hardship exclusion on a case-by-case basis. This was especially necessary during the pandemic. This allows them to avoid potential penalties associated with the PI category and continue participation in the MIPS program.  

CMS grants hardship exceptions for the following reasons: 

  • Insufficient internet connectivity 
  • Extreme and uncontrollable circumstances 
  • Lack of control over the availability of Certified EHR Technology (CEHRT) 
  • Lack of face-to-face interaction 
  • Practice Size 
  • Disaster or Public health emergency 

By granting hardship exceptions, CMS allows eligible healthcare professionals to focus on providing high-quality care to patients without the additional burden of the PI category requirements. 

Key Objectives and Measures of MIPS Promoting Interoperability in 2023 

Achieving the key objectives and measures of MIPS promoting interoperability in 2023 is critical for healthcare professionals to improve patient outcomes and healthcare delivery. Through increased exchange of information between providers and better use of technology the following objectives are met. 

Objective 1: Patient Access 

Patient access to health records is important because it increases patients’ engagement in their healthcare decisions and ensures continuity of care across different healthcare systems. To achieve this objective, healthcare professionals must identify the right patient messaging tool for their practice, educate their patients on how to use it, and ensure secure messaging protocols are in place. Patient access is a cornerstone of interoperability. In 2023, MIPS is being updated to prioritize patient access to their health information. Physicians must use at least one secure patient messaging tool to communicate with their patients.  

Objective 2: Health Information Exchange 

The second objective is focused on improving the exchange of health information between providers through interoperability. Healthcare professionals must electronically submit summary care records for transitions of care to another setting or provider. This objective paves the way for better coordination of care, reducing medication errors, and minimizing duplicate testing. To achieve this objective, healthcare professionals must identify sources of patient information, establish secure communication channels between providers, and implement data validation processes. 

Objective 3: Public Health and Clinical Data Registry Reporting 

The third objective is to improve population health outcomes through public health and clinical data registry reporting. Physicians must submit data to a public health registry or clinical data registry for at least one measure.  

This objective has been updated to increase accountability for institutions that refuse to submit data, and a penalty may be imposed if thresholds are not met. To achieve this objective, healthcare professionals must identify the most relevant registry for their practice, develop an efficient data management workflow, and ensure quality data is submitted on time. 

Objective 4: Clinical Decision Support 

The final objective is focused on the use of clinical decision support (CDS) tools to improve patient outcomes. Clinicians must establish and implement at least one CDS intervention related to a high-priority health condition. This objective helps to improve health outcomes by promoting evidence-based medical practices. To achieve this objective, healthcare professionals must identify preferred CDS tools for their practice, develop workflows that integrate CDS interventions with patient care activities, and monitor and report on the effect of CDS interventions on patient outcomes. 

MIPS PI CEHRT Requirements 

One of the key provisions of MACRA is the Merit-based Incentive Payment System (MIPS), which incentivizes healthcare providers to report on quality measures, Improvement Activities (IAs), and Advancing Care Information (ACI). MIPS PI CEHRT requirements are a crucial component of the ACI component of MIPS. 

CEHRT stands for Certified Electronic Health Record Technology, defined as electronic health record technology that meets specific certification criteria set by the Office of the National Coordinator for Health Information Technology (ONC). The Certified Health IT Product List (CHPL) provides an authoritative, comprehensive listing of health IT modules tested and certified through the ONC Health IT Certification Program.  

To be eligible for MIPS incentives, providers need to use CEHRT that meets the MIPS PI requirements. The MIPS PI CEHRT requirements focus on four measures: 

  1. Electronic prescribing (e-Prescribing) 
  1. Health information exchange (HIE) 
  1. Patient access to health information 
  1. Provider to patient exchange of health information 

To meet these requirements, healthcare entities need to use certified EHR technology to perform these functions. The certified EHR technology should be capable of electronically transmitting health information to other healthcare providers, as well as to the patients themselves. 

How to Report Your MIPS PI Data 

Before you start reporting your PI data, it is important to review the requirements thoroughly. The MIPS PI category consists of four objectives: e-Prescribing, Health Information Exchange (HIE), Provider-to-Patient Exchange, and Public Health and Clinical Data Exchange.  

Each objective has specific measures that you must report against. Familiarize yourself with the measures and determine which ones apply to your practice or specialty. Make sure you understand the criteria for success, as some measures require a minimum percentage of performance. 

Choose the Right Reporting Mechanism 

There are two options for reporting PI data: the Medicare Promoting Interoperability Program Portal and the Electronic Health Record (EHR) Incentive Program Registration and Attestation System. Both options have their advantages and disadvantages, so you need to weigh them carefully. Using the Medicare Portal allows for real-time tracking of your data. However, if you are already registered with the program, using the EHR Incentive Program Registration and Attestation System is simpler. 

Monitor Your Progress Regularly 

The feedback report on the Medical Portal allows you to monitor your progress regularly. The report shows your performance on each measure and is updated every 24 hours. By regularly reviewing the report and identifying improvements, you can adjust your workflow or EHR system as needed. 

Keep Up with Changes in the Program 

The MIPS program, including the PI category, is constantly evolving. It is essential to stay up to date with any changes to the program that may affect your reporting. Changes can occur in the requirements, measures, and reporting mechanisms. You can stay informed by checking the Centers for Medicare & Medicaid Services (CMS) website regularly, and also access education and outreach materials to help navigate the program updates. 

Seek Assistance If Needed 

Finally, if you are struggling to report your PI data, there is help. The CMS website provides a list of resources that can help you, including local Technical Assistance resources and Quality Innovation Network-Quality Improvement Organizations. Additionally, an experienced healthcare consulting firm can be a valuable resource for understanding the reporting requirements and measures. Connecting with the right resources to overcome these obstacles is imperative as reporting your PI data correctly is crucial for your incentives and your patients. 

Summary: MIPS Promoting Interoperability Measures   

Reporting your MIPS PI data is an essential component of the MIPS program. A strategy for PI success includes reviewing the requirements, choosing the right reporting mechanism, monitoring your progress regularly, keeping up with changes in the program, and seeking assistance if needed. By following these tips, you can ensure that you are reporting your PI data accurately and efficiently. Remember that reporting your data correctly is not only vital for your payments but also for improving patient outcomes and quality of care. 

Get on Track with MIPS PI Measures 

Medical Advantage provides a comprehensive assessment and support services to help healthcare providers successfully navigate the Merit-Based Incentive Payment System (MIPS). Our healthcare consultants offer a full practice assessment and security risk analysis to uncover improvement opportunities in all categories of MIPS.  

In addition, our Accountable Care Organization (ACO) offers comprehensive support for achieving top-performer status under MIPS. Whether you are a small practice or part of a larger health system, we can help. Contact us today for more information on how your practice can benefit from MIPS. 


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