What is Promoting Interoperability and MIPS?

What is Promoting Interoperability?

Promoting interoperability was formerly known as “Meaningful Use” under the ARRA HITECH Act of 2009.  Promoting interoperability promotes patient engagement and electronic exchange of information using certified electronic health record technology (CEHRT).  Promoting interoperability is heavily weighted in the Merit-Based Incentive Payment System known as MIPS (see below).   Achieving the performance measure is worth 25% of the MIPS Final Score in 2022.  If a physician qualifies as an Eligible Clinician, they report objectives and measure data collected in one of the three CEHRT options below.

MIPS-eligible clinicians report Promoting Interoperability data using one of these three options:

  • 2015 Edition, or
  • 2015 Edition Cures Update
  • A combination of both

The Electronic Health Record must meet several core functions for MIPS reporting.  These include “Provide Patients Electronic Access to Their Health Information”

PI_PEA_1  – For at least one unique patient seen by the MIPS eligible clinician:

(1) The patient (or the patient-authorized representative) is provided timely access to view online, download, and transmit his or her health information; and

(2) The MIPS-eligible clinician ensures the patient’s health information is available for the patient (or patient-authorized representative) to access using any application of their choice that is configured to meet the technical specifications of the Application Programming Interface (API) in the MIPS eligible clinician’s certified electronic health record technology (CEHRT).

There are corresponding certification criteria that apply:

§170.315(e)(1) View, Download, and Transmit to 3rd Party

§170.315(g)(7) Application Access — Patient Selection

§170.315(g)(8) Application Access — Data Category Request

§170.315(g)(9) – All Data Request The three criteria combined are the ‘‘API’’ certification criteria

When is the Promoting Interoperability Reporting Period?

There is a minimum EHR reporting period of 90 consecutive days

How do ECs Meet the 2022 Medicare Promoting Interoperability Requirements?

  • ECs must report against the four objectives and associated measures:
    • Public Health and Clinical Data Exchange
    • Health Information Exchange
    • Provider to Patient Exchange
    • Electronic Prescribing
  • Report on three electronic clinical quality measures (aka eCQMs) and the safe use of opioids
  • ECs may select three-quarters of data for Prescribing eCQM using three self-selected quarters of data.
  • Must also attest to the following Standards:
    • Security Risk Analysis measure
    • The ONC direct review attestation from the Office of the National Coordinator for Health IT
    • Identify any actions to limit or restrict the compatibility or interoperability of CEHRT attestation
    • Provide the Safety Assurance Factors for EHR Resilience (SAFER) Guides

If Eligible Clinicians (ECs) select the last 90-days in 2022 as the performance period, then the 2015 Edition CEHRT (or 2015 Edition Cures update or a combination) must be in use by October 3, 2022.   ECs must have a certified EHR for the 2015 Edition by December 31, 2022.

What is MIPS?

The Merit-Based Incentive Payment System (MIPS) determines the Medicare payment adjustments.  Using a composite performance score, eligible clinicians (ECs) may receive:

  1. a payment bonus,
  2. a payment penalty,
  3. no payment adjustment.

How Can one Determine how to Participate in MIPS?

CMS provides that provider eligibility status is specific to each practice as identified by a taxpayer indentation number that a provider is  associated with and is based on the following four factors:

  • clinician type;
  • date of Medicare provider enrollment
  • whether a clinician meets or exceeds all three elements of the low-volume threshold; and
  • Whether a clinician achieved Qualifying APM Participant (QP) status

Do the MIPS Quality Measures Vary by Medical Specialty?


The number of MIPS quality measures varies by medical specialty, and are worth up to 30% of the overall score, along with 25% for promoting interoperability, 15% for improvement activities

When do ECs receive payment for MIPS and Promoting Interoperability reporting?

These steps must be completed to receive payment

  1. First check eligibility to report and participate
  2. Understand the reporting options and collect the data
  3. Verify eligibility and required reporting Standards
  4. Report the data
  5. Review MIPS performance feedback
  6. Receive a neutral, or negative payment


QPP Participation Status tool enables clinicians to view their eligibility status.

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Michael F. Arrigo

Michael Arrigo, an expert witness, and healthcare executive, brings four decades of experience in the software, financial services, and healthcare industries. In 2000, Mr. Arrigo founded No World Borders, a healthcare data, regulations, and economics firm with clients in the pharmaceutical, medical device, hospital, surgical center, physician group, diagnostic imaging, genetic testing, health I.T., and health insurance markets. His expertise spans the federal health programs Medicare and Medicaid and private insurance. He advises Medicare Advantage Organizations that provide health insurance under Part C of the Medicare Act. Mr. Arrigo serves as an expert witness regarding medical coding and billing, fraud damages, and electronic health record software for the U.S. Department of Justice. He has valued well over $1 billion in medical billings in personal injury liens, malpractice, and insurance fraud cases. The U.S. Court of Appeals considered Mr. Arrigo's opinion regarding loss amounts, vacating, and remanding sentencing in a fraud case. Mr. Arrigo provides expertise in the Medicare Secondary Payer Act, Medicare LCDs, anti-trust litigation, medical intellectual property and trade secrets, HIPAA privacy, health care electronic claim data Standards, physician compensation, Anti-Kickback Statute, Stark law, the Affordable Care Act, False Claims Act, and the ARRA HITECH Act. Arrigo advises investors on merger and acquisition (M&A) diligence in the healthcare industry on transactions cumulatively valued at over $1 billion. Mr. Arrigo spent over ten years in Silicon Valley software firms in roles from Product Manager to CEO. He was product manager for a leading-edge database technology joint venture that became commercialized as Microsoft SQL Server, Vice President of Marketing for a software company when it grew from under $2 million in revenue to a $50 million acquisition by a company now merged into Cincom Systems, hired by private equity investors to serve as Vice President of Marketing for a secure email software company until its acquisition and multi $million investor exit by a company now merged into Axway Software S.A. (Euronext: AXW.PA), and CEO of one of the first cloud-based billing software companies, licensing its technology to Citrix Systems (NASDAQ: CTXS). Later, before entering the healthcare industry, he joined Fortune 500 company Fidelity National Financial (NYSE: FNF) as a Vice President, overseeing eCommerce solutions for the mortgage banking industry. While serving as a Vice President at Fortune 500 company First American Financial (NYSE: FAF), he oversaw eCommerce and regulatory compliance technology initiatives for the top ten mortgage banks and led the Sarbanes Oxley Act Section 302 internal controls I.T. audit for the company, supporting Section 404 of the Sarbanes Oxley Act. Mr. Arrigo earned his Bachelor of Science in Business Administration from the University of Southern California. Before that, he studied computer science, statistics, and economics at the University of California, Irvine. His post-graduate studies include biomedical ethics at Harvard Medical School, biomedical informatics at Stanford Medical School, blockchain and crypto-economics at the Massachusetts Institute of Technology, and training as a Certified Professional Medical Auditor (CPMA). Mr. Arrigo is qualified to serve as a director due to his experience in healthcare data, regulations, and economics, his leadership roles in software and financial services public companies, and his healthcare M&A diligence and public company regulatory experience. Mr. Arrigo is quoted in The Wall Street Journal, Fortune Magazine, Kaiser Health News, Consumer Affairs, National Public Radio (NPR), NBC News Houston, USA Today / Milwaukee Journal Sentinel, Medical Economics, Capitol ForumThe Daily Beast, the Lund Report, Inside Higher Ed, New England Psychologist, and other press and media outlets. He authored a peer-reviewed article regarding clinical documentation quality to support accurate medical coding, billing, and good patient care, published by Healthcare Financial Management Association (HFMA) and published in Healthcare I.T. News. Mr. Arrigo serves as a member of the board of directors of a publicly traded company in the healthcare and data analytics industry, where his duties include: member, audit committee; chair, compensation committee; member, special committee.

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