MIPS 2022: Promoting Interoperability

In the 2022 Merit-based Incentive Payment System (MIPS) performance year, the Promoting Interoperability (PI) category remains 25% of an individual clinician's or group's overall MIPS score. Although the measures have only slight changes, the category as a whole is undergoing some key modifications. The PI measures continue to be divided among 5 main objectives. 

The biggest category changes are that CMS has: 

1. An added mandatory scoreless prerequisite,

2. Slightly changed a couple category measures, and 

3. Offered certain participants the option to circumvent reporting the PI category altogether and reweight its 25% to other categories. 

Scoreless Prerequisite 

To date, the scoreless PI prerequisites have included:

1. The ONC Direct Attestation Statement, 

2. Completion of a Security Risk Analysis, and 

3. Attestation regarding Information Blocking. 

In 2022, participants who report this category will also need to attest to their compliance of the SAFER guidelines. There are a total of 9 SAFER guidelines organized into three broad groups that enable healthcare organizations to address EHR safety in a variety of areas. They include:

1. Foundational Guides 

2. Infrastructure Guides 

3. Clinical Process Guides

Most organizations will want to start with the Foundational Guides and proceed from there to address the areas of greatest interest or concern for their organization. Each group of guides will require time, education, and effort to complete. Be sure to allot  time for this new requirement in 2022. 

Measures and Requirements

Regarding measure updates, participants can earn up to 15 bonus points for submitting a “yes” response for the optional measure: Query of Prescription Drug Monitoring (PDMP). This is a two-part requirement, but offers reporters an accessible option to improve their category score. 

Separately, for the Public Health and Clinical Data Exchange objective, participants will be awarded full points if a “yes” is submitted for the 2 required measures (i.e., Immunization Registry and Electronic Case Reporting) or one “yes” and one exclusion. 

As a reminder, you must report all required measures (submit a “yes”/report at least 1 patient in the numerator, as applicable, or claim an exclusion) or you will earn a zero for the Promoting Interoperability performance category. Participants must report all required measures or they will earn a zero for the Promoting Interoperability performance category. 

Reweighting

Beginning with the 2022 performance period, some clinicians will be automatically reweighted based on:

• Special status (i.e.,, hospital-based clinicians),

• Clinician type (i.e.,, a physical therapist, occupational therapist, clinical psychologist, or clinical social worker), or;

• If they are a part of a small practice (i.e., 15 clinicians or fewer).

Clinicians who meet the above criteria will not need to submit a PI hardship exception application. The category points will be reallocated to another performance category (or categories) based on the submission. 

Small practices can elect to report and still earn points in the PI category. Choosing to participate in PI can be a strategic move to improve an organization’s overall score based on other category participation and performance. 

One thing is for sure, PI is to be carefully considered. In trying to achieve 75 points to avoid a penalty AND 89 POINTS to achieve Exceptional Performance, every point earned equates to additional reimbursement potential. 

If you need expert help to understand the PI measures, complete the new SAFER guidelines with ease, or you want to understand the what-if scenarios of PI participation as a whole, give us a call. Phone 888-647-7247 or email us at hello@chirpybirdinc.com