Introduction to the Merit-based Incentive Payment System (MIPS)

Overview

The Merit-based Incentive Payment System (MIPS) is a key component of the Quality Payment Program (QPP), introduced in 2017. This initiative aims to transition Medicare Part B providers to a performance-based payment model. MIPS consolidated three existing quality-reporting programs—PQRS, VBM, and MU—into a unified system that assesses performance through a scoring mechanism known as the MIPS composite or final score.

Categories of MIPS

MIPS evaluates performance across four main categories:

Quality

Improvement Activities (IA)

Promoting Interoperability (PI)

Cost

Each category contributes a specific percentage to the final score, directly influencing the positive payment adjustment clinicians receive based on their performance during the year. It is essential to note that the criteria and guidelines for these categories are subject to annual updates, including for MIPS 2021.

Focus on Promoting Interoperability (PI)

Category Overview

The Promoting Interoperability (PI) category, which accounts for 25% of the final MIPS score, replaces the Medicare Electronic Health Records Incentive Program. It emphasizes patient engagement and information sharing using Certified Electronic Health Record Technology (CEHRT).

Categories and Measures

The PI category includes 11 measures organized into four objectives:

1. Electronic Prescribing (e-prescribing)

This objective consists of two measures. Clinicians must write at least one prescription and transmit it electronically via CEHRT, earning 10 points. Additionally, there is a bonus measure for using the Prescription Drug Monitoring Program (PDMP), which also requires at least one Schedule II opioid to be prescribed electronically, worth another 10 points.

2. Provider to Patient Exchange

This objective includes a single measure that mandates clinicians provide patients or their representatives access to their healthcare information. This access must comply with the Applications Programming Interface (API) specifications in CEHRT and is valued at 40 points for MIPS 2021 reporting.

3. Health Information Exchange

This objective comprises three measures presented in two options:

– **Option 1**:
– Support Electronic Referral Loops by Submitting Health Information, which requires creating and exchanging a summary of care record electronically, worth 20 points.
– Support Electronic Referral Loops by Receiving & Reconciling Health Information, worth 20 points.

– **Option 2**:
– Health Information Exchange (HIE) Bi-Directional Exchange, which supports transitions of care and is valued at 40 points.

Clinicians can choose between these options based on their reporting preference.

4. Public Health and Clinical Data Exchange

This category includes five measures, from which clinicians must select two for reporting, each worth a total of 10 points. The measures focus on active engagement with public health agencies for immunization reporting, syndromic surveillance, electronic case reporting, public health registry reporting, and clinical data registry reporting.

Reporting and Submission Criteria

Clinicians can gather data for the measures using an Electronic Health Record (EHR) that meets specific certification criteria. Reporting data generally spans a consecutive 90-day period. Along with submitting the measures, clinicians must provide their EHR’s CMS Identification Code from the Certified Health IT Product List (CHPL). They must also affirm compliance with various attestations.

Data for MIPS 2021 reporting can be submitted by:

– The clinicians themselves
– A representative from a practice, virtual group, or APM Entity
– Third-party intermediaries, such as a Qualified Registry

Hardship Exceptions

Clinicians may apply for a Promoting Interoperability Performance Category Hardship Exception, which allows them to forgo participation in this category if they meet specific criteria, including being from a small practice or facing uncontrollable circumstances. If approved, they will receive a score of 0% in the PI category, which will then be redistributed to other objectives. Special status clinicians may be exempt from submitting this application.

Conclusion

For MIPS eligible clinicians, understanding the nuances of the Promoting Interoperability category is vital for effective strategy formulation. Engaging a MIPS Qualified Registry can streamline the timely submission of MIPS 2021 data to CMS. For more information on the program, visit the following link: https://p3healthcaresolutons.blogspot.com/2021/09/avoid-penalty-for-mips-2021.html.