Are you on the right track in the MIPS Promoting Interoperability (PI) category this year? With year-over-year changes, exemptions, and new provider types in the MIPS program, it’s easy to find yourself lost in the rules. In this blog post, we’ll cover four common questions we see from Mingle Health customers concerning Promoting Interoperability in 2022.
If you have additional questions about MIPS Promoting Interoperability or the MIPS program in general, click here to get in touch with one of our Mingle Health experts.
MIPS Promoting Interoperability Questions
“I did well in MIPS Promoting Interoperability in 2021. Will I do well again in 2022?”
That depends. There are some changes to the Public Health and Clinical Data Exchange Objective. New this year, Immunization Registry Reporting and Electronic Case Reporting are required measures. You’ll need to either attest that you are in active engagement or that you are excluded from these two measures. If you are in active engagement with one of the other three registry types, you can get five bonus points (but no extra points for active engagement with more than one bonus registry).
“Is there something new I need to do for Protect Patient Health?”
Yes! In addition to the Security Risk Assessment, which you have been doing (also a HIPAA requirement), you need to attest that you have conducted an annual assessment of the High Priority Practices SAFER Guides. The SAFER guides contain nine different guides. CMS is asking you to attest specifically regarding the “High Priority Practices” guide, which is one of the nine. You can find these guides online: HealthIT.gov SAFER Guides
“I work in a small practice. Can I apply for the MIPS Promoting Interoperability Hardship again this year?”
Great news! You don’t even need to apply this year. While CMS still encourages small practices to utilize EHR systems, they recognize that this can sometimes be burdensome. New for 2022, they have instituted an automatic PI Exemption if CMS has identified you as working in a small practice. So, you do not need to apply. Your PI points will automatically be re-weighted if you do not submit PI data. If you report PI data, CMS will calculate and weight the PI category as it has in the past. If you have the small status designation and do not report PI for any reason (including hospital-based or non-patient facing), you will also get a special re-weighting of the PI category. In this circumstance, Quality will be worth 40%, Improvement Activities worth 30%, and Cost worth 30%.
“Do I need to report PI for the new MIPS provider types?”
CMS encourages all MIPS provider types to report Promoting Interoperability if they can. However, they also recognize that not all provider types utilize the EHR in ways calculated by the current PI measures, so some providers are exempt from reporting PI. Clinical social workers are on the list of providers exempt from reporting PI. There is no automatic re-weighting for certified nurse-midwives, so they must report PI.
Reminder: Promoting Interoperability is reported for any 90-day reporting period in 2022, and any PI hardships you apply for need to be submitted to CMS by 12/31/2022.
If you’re a Mingle Health customer and have additional questions, don’t hesitate to contact your consultant today. For non-customers, you can send your questions to our MIPS experts here.
Click the button below to access the recording of our 2022 MIPS webinar - "The Hardest Year Yet: Your MIPS Success in 2022" - where Dr. Dan Mingle provides an in-depth exploration of the MIPS program this year.