How has the Merit-Based Incentive System and Promoting Interoperability replaced Meaningful Use?

As a result of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) and the conclusion of ARRA HITECH Act stimulus payments, the Meaningful use of Electronic Health Record program concluded.  Now that the majority of healthcare providers are using an E.H.R., the philosophy and emphasis are on improving the ability to share or ‘interoperate’ between physicians, hospitals, laboratories and other providers who may be using electronic records systems.

What is the Merit-based Incentive Payment System?

The Merit-based Incentive Payment System (MIPS) is one way to participate in the Quality Payment Program (QPP), a program authorized by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The program describes how Medicare reimburses MIPS-eligible clinicians for Part B-covered professional services and rewards them for improving the quality of patient care and outcomes. 

What is the Promoting Interoperability Performance Category?

The MIPS Promoting Interoperability performance category focuses on the electronic exchange of health information using certified electronic health record technology (CEHRT). It is focused on improving: 

  1. Patient access to their health information;
  2. The exchange of information between clinicians and pharmacies; and 
  3. The systematic collection, analysis, and interpretation of healthcare data.

What’s New with Promoting Interoperability in 2022?

  1. For 2022, Automatic reweighting was updated by the Centers for Medicare and Medicaid in the Promoting Interoperability performance category.   No hardship Promoting Interoperability Hardship Exception is required for Clinical social workers and small practices for automatic reweighting
  2. The High Priority Practices Guide was added by CMS.  This is a new required but unscored attestation measure, and a component of the required Safety Assurance Factors for EHR Resilience (SAFER) Guides measure.
  3. Revised: Prevention of Information Blocking attestation statements to distinguish this attestation from the separate information blocking policies established in the 21st Century Cures Act final rule. This attestation has been renamed Actions to Limit or Restrict Interoperability of CEHRT.
  4. Revised: the Public Health and Clinical Data Exchange objective requirements to support public health agencies
  5. Clinicians are required to report
    • Immunization Registry Reporting and
    • Electronic Case Reporting measures.
  6. Fourth exclusion for the Electronic Case Reporting measure, available for the PY 2022 only.
  7. Optional reporting:
    • Public Health Registry Reporting, OR
    • Clinical Data Registry Reporting, OR
    • Syndromic Surveillance Reporting measures for five bonus points.

How to Start with Promoting Interoperability for Traditional MIPS

  1. Understand  Reporting Requirements
  2. Review the CEHRT Requirements
  3. Review the Measures and Performance Period Requirements
  4. Perform or Review a Security Risk Analysis
  5. Submit Data

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