Keeping pace with regulatory requirements like MIPS can be a daunting task for physician practices. To help our ChartPath clients save time and keep them on track, we are unpacking the Promoting Interoperability (PI) measure, which mandates providers to demonstrate their commitment to EHR utilization to meet some key objectives and non-EHR requirements for the new 180-day reporting period. Let’s take a look at the PI basics for 2024.
Understanding Promoting Interoperability
The MIPS Promoting Interoperability measure, formerly known as the Meaningful Use program, focuses on promoting the seamless exchange of health information between providers and patients. It aims to enhance patient engagement, improve care coordination, and facilitate the exchange of health information securely.
What It Means for Providers
For healthcare providers participating in MIPS, meeting the Promoting Interoperability measure is essential for achieving a positive payment adjustment and avoiding penalties. The measure evaluates how well providers utilize certified electronic health record technology (CEHRT) to promote interoperability and improve patient outcomes.
The 180-Day Requirement
One specific aspect of the Promoting Interoperability measure that providers must adhere to in 2024 is the 180-day reporting requirement. This means that eligible clinicians must demonstrate the meaningful use of CEHRT for a continuous 180-day period during the MIPS performance year. This period can be any 180 consecutive days within the calendar year. With nearly half of the year already gone, the time to get started is NOW to ensure compliance.
Who Has to Report
Certain clinician types and special status designations result in automatic reweighting, exempting them from reporting Promoting Interoperability data for the 2024 performance year:
- Clinician type: Clinical Social Workers
- Special status: Ambulatory surgical center (ASC)-based, hospital-based, non-patient facing, and small practice (Note: small practice is the only special status available to APM Entities.)
If you’re reporting as a group, virtual group, or APM Entity, all MIPS eligible clinicians must qualify for re-weighting for the group to be re-weighted, unless the group has a special status that qualifies them for automatic re-weighting.
Beginning with the 2024 performance year, the following clinician types will no longer be automatically re-weighted and are therefore required to report Promoting Interoperability data:
- Physical therapists
- Occupational therapists
- Qualified speech-language pathologists
- Qualified audiologists
- Clinical psychologists
- Registered dietitians or nutrition professionals
- The PI Objectives
To meet the Promoting Interoperability measures during the 180-day requirement, providers must focus on several key areas:
- Electronic Prescribing (e-prescribing)
- This objective includes two elements:
- Fully utilize electronic prescribing for prescriptions.
- Query the Prescription Drug Monitoring System before ordering Schedule II, III, and IV drugs.
- Health Information Exchange
This requirement can be met in one of three possible ways for each inbound or outbound referral:
- Send/receive patient information within the integrated EHR system.
- Share health information through a Health Information Exchange (HIE).
Use a TEFCA-based exchange, ensuring the EHR vendor is connected to a Qualified Health Information Network (QHIN).
Provider to Patient Exchange
Ensure the patient portal is enabled for new and existing patients to view, download, and transmit their information consistently within four business days of their visit.
Public Health and Clinical Data Exchange
This objective requires active engagement with a public health agency to submit data to public health registries. Active engagement means working towards, or already sending, "production data" to a PHA or CDR.
- The first measure objective includes:
- Immunization Registry and Electronic Case Reporting.
- The second measure includes:
- Public Health or Clinical Data Registry or Syndromic Surveillance Reporting.
Non-EHR Promoting Interoperability Requirements
In addition to submitting measures, you must provide your EHR’s CMS identification code from the Certified Health IT Product List (CHPL) and submit a “yes” to:
Actions to Limit or Restrict Compatibility or Interoperability of CEHRT (previously named the Prevention of Information Blocking) Attestation.The ONC Direct Review Attestation.The Security Risk Analysis (SRA) Measure.The Safety Assurance Factors for EHR Resilience (SAFER) Guides Measure.
Bonus Points
Earn five bonus points for submitting a "yes" response for one of the optional Public Health and Clinical Data Exchange measures (Public Health Registry Reporting, Clinical Data Registry Reporting, or Syndromic Surveillance Reporting).
How Are Measures Scored?
For measures requiring a numerator and denominator, we calculate the performance rate for each measure using the submitted numerators and denominators, then multiply the performance rate by the total points available for the measure or objective. For "yes" or "no" measures, full points are awarded for "yes" responses.
For the Public Health and Clinical Data Exchange objective, full points are awarded if a “yes” is submitted for the two required measures (Immunization Registry Reporting and Electronic Case Reporting) or one “yes” and one exclusion. Report all required measures or claim exclusions to avoid earning zero for the Promoting Interoperability performance category.
Participation in MIPS is mandatory for eligible clinicians. Meeting specific measures within MIPS, such as Promoting Interoperability, can vary based on individual circumstances. However, failing to meet the requirements can result in financial penalties and a negative impact on reimbursement rates. The Promoting Interoperability category is not to be overlooked, and the need to comply with a 180-day reporting period means getting started earlier is more important than ever.
Questions about MIPS? Call ChartPath or email us at support@chartpath.com or contact our consulting partner, Chirpy Bird, for more details on these measures, and all categories. They help clients use their existing EHR to succeed in all MIPS categories; PI, Quality, Improvement Activities, and even Cost! They offer pay-as-you-go monthly support that aligns you with a dedicated resource to support your best MIPS score and reimbursement.
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