In this episode, Dr. Dan Mingle answers questions from Jamie and Lisa about the impact of Promoting Interoperability performance on ACOs with the updated PI requirements for 2025, and when a practice can file for an exception from the Cost performance category in MIPs.

Click play on the video below to listen to this episode now, or scroll down for the written summary.

Question One: Impact of Promoting Interoperability Performance on ACOs

Lisa asks: “How will ACOs, now responsible for assuring all participants report Promoting Interoperability (PI), be impacted by the actual performance of all participating TINs?”

Great question, Lisa.

2025 is the year that the rule goes into effect that all ACO participants are expected to use certified EHR technology AND to make a Promoting Interoperability submission.

In prior years, 75% of Advanced APM participants and 50% of MIPS APM participants were required to use CEHRT.

There are a couple of caveats in the new requirements:

• There is a big loophole in the requirement. All of the exceptions that exist for the MIPS Promoting Interoperability performance category apply to the CEHRT use requirement in ACOs including:
  • Small practices
  • Facility-based practices
  • And non-patient facing practices
• The use of CEHRT is a contractual requirement built, now, into all ACO contracts with CMS. There is not a scoring requirement, just a submission requirement. Neither the individual scores nor the composite ACO score factors into ACO performance or collection of shared savings.

Before you conclude that the actual scoring of Promoting Interoperability is irrelevant, there is one more factor to keep in mind: Though the ACO will not experience any differential payment based on the Promoting Interoperability scoring, that is not true of the participating TIN-Practices or the participating NPI-providers.

Those practices and providers that are MIPS-liable will have a MIPS adjustment to which the Promoting Interoperability score is important. Even though the Promoting Interoperability score will not affect ACO collection of shared savings, it will affect MIPS adjustment of Medicare payments to practices and providers.

• In a MIPS APM: Every practice and provider in a MIPS APM will have a MIPS adjustment.
• In an Advanced APM: Every provider in an advanced APM that doesn’t achieve Qualified Participant (QP) status will have payments effected by the MIPS adjustment, to which the PI score applies.

Question Two: MIPS Cost Category Exceptions

Jamie asks: “When can a practice file for an exception to the Cost performance category?”

Great question, Jamie.

You are referring to an Extreme and Unusual Circumstances (EUC) application relating to MIPS scoring issues.

Technically, any or all elements of MIPS scoring are subject to EUC exceptions. The application window typically opens in April of each performance year and closes when the calendar year ends. Though there are occasionally special circumstances that extend the application window.

That said, the Cost performance category is not typically something that is waived.

Not everyone is scored on Cost.

There are two automatic exceptions for Cost measures.

Exception One: Case-minimums

• In traditional MIPS submissions, a provider or practice will be scored on every Cost measure for which they have case minimums for the measure.
• In MVPS, a provider or practice will be scored on all of the Cost measures included in the MVP for which they have case minimums for the measure.

Exception Two: APM Participation

• Part of every APM contract is differential payment based on cost of care.
• Because cost is a factor in payment, APM participants who are subject to MIPS adjustments are automatically excepted from Cost scoring.

Though I’ve not seen the Cost category excepted through the EUC process for any practice or provider, I can imagine a compelling argument in an EUC application that could win an exception. If you believe such a circumstance exists for you, make an application. Application is available on the Quality Payment Program website. Keep an eye on the QPP website for the opening of the application window.

Want to learn more about MIPS in 2025?

Our PDF guide provides critical information for MIPS participants in the 2025 Performance Year.

Access the Guide