In the MIPS program, the Promoting Interoperability (PI) category replaces the Medicare Electronic Health Records (EHR) Incentive Program (Meaningful Use) and is intended to promote patient engagement and the electronic exchange of information using certified EHR technology (CEHRT). Beginning in 2019, you will submit a single set of Promoting Interoperability Objectives and Measures to align with the 2015 Edition CEHRT.
Certified EHR Technology (CEHRT)
To be considered a meaningful user and avoid a downward payment adjustment, eligible hospitals and CAHs attesting to the Medicare Promoting Interoperability Program will be required to use CEHRT that has been updated to meet 2015 Edition Cures update criteria (unless an exclusion is claimed).
The CY 2023 CEHRT requirements for the Medicare Promoting Interoperability Program are as follows:
2015 Edition Cures update functionally must be used as needed for a measure action to count in the numerator during EHR reporting period chosen by the eligible hospital or CAH (a minimum of any continuous 90 days in 2023).
In some situations, the product may be deployed during the EHR reporting period but pending certification. In such cases, the product must be updated to the 2015 Edition Cures Update criteria by the last day of the EHR reporting period.
Eligible hospitals and CAHs must provide their EHR's CMS Identification code from the Certified Health IT Product List (CHPL), available on HealthIT.gov, when submitting their data.
Certified EHR Technology (CEHRT)
Participants are required to report on four scored objectives and their measures:
1. Electronic Prescribing
2. Health Information Exchange
3. Provider to Patient Exchange
4. Public Health and Clinical Data Exchange
Participants are also required to report (yes/no) on the Protect Patient Health Information objective:
Security Risk Analysis measure
Safety Assurance Factors for EHR Resilience (SAFER) Guides measure
CMS continues to implement a performance-based scoring methodology. Each measure will contribute to the eligible hospital or CAH's total Medicare Promoting Interoperability Program score. A minimum of 60 points is required to satisfy the scoring requirement.
In addition to submitting measures, clinicians must submit a “yes” to:
The Prevention of Information Blocking Attestation,
The ONC Direct Review Attestation, and;
The security risk analysis measure
A clinician or group participating in MIPS may submit a Promoting Interoperability Hardship Exception Application, citing one of the following reasons for review and approval:
MIPS eligible clinician in a small practice
MIPS eligible clinician using decertified EHR technology
Insufficient internet connectivity
Extreme and uncontrollable circumstances
Lack of control over the availability of CEHRT
For clinicians participating in MIPS, getting a hardship exception means that the Promoting Interoperability performance category receives zero weight in calculating your final score and the 25% is reallocated to the Quality performance category. There are some clinicians who will be automatically re-weighted based on special status (for example, hospital-based clinicians) or their clinician type (for example, a physical therapist, occupational therapist, or clinical psychologist). These clinicians will not need to submit a Promoting Interoperability Hardship Exception Application. If you're submitting as part of a practice, the whole practice must qualify for some sort of hardship exception for the group to be reweighted.
Qualifying clinicians may choose from a variety of methods for submitting PI measures: