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MIPS Promoting Interoperability in 2023: Common Questions Answered

Are you on the right track for MIPS Promoting Interoperability in 2023? 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 some general questions we see from Mingle Health customers concerning Promoting Interoperability in 2023.

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.

“Who needs to report MIPS Promoting Interoperability in 2023?”

Clinical social workers, physical therapists, occupational therapists, qualified speech-language pathologists, qualified audiologists, clinical psychologists, and registered dieticians or nutrition professionals continue to qualify for automatic reweighting.

CMS now requires PI reporting for nurse practitioners, physician assistants, certified registered nurse anesthetists and clinical nurse specialists. These (and other MIPS PI providers) can still qualify for automatic re-weighting if they have a special status, such as hospital based, non-patient facing and/or small practice. You still have the option of filing for a PI hardship, if you meet the hardship requirements.

Reminder: Promoting Interoperability is reported for any 90-day reporting period in 2023, and any PI hardships you apply for need to be submitted to CMS by 1/2/2024.

“My EHR vendor is telling me that I need to make some updates to my system for Promoting Interoperability in 2023. Do I need to do that?”

For 2023 reporting, your EHR must be certified to the 2015 Edition Cures Update certification criteria for the 2023 performance period.

  • Functionality must be in place by the start of the performance period with certification obtained by the last day of the performance period.

It’s very important that you work with your vendor to implement updates which pertain to this upgrade. You may also consider filing for a PI hardship related to vendor issues if that is applicable. If you choose to file for a hardship, you should keep all your documentation relating to the ongoing issues you may have had with your vendor.

“Are there any changes to Protect Patient Health?”

No, you are still required to conduct a Security Risk Analysis (also a HIPAA requirement). In addition, you need to attest whether or not 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: SAFER Guides

“What are the changes to the Public Health and Clinical Data Exchange Objective?”

  1. For the mandatory Electronic Case Reporting measure there are only three exclusions (versus four in 2022). Make sure you are either in active participation with a registry or can qualify for one of the current exclusions.
  2. New this year: all responses of “yes” for any of the registry measures require an answer of which level of active engagement the provider/practice is in. The two options to choose from are either “Pre-production and Validation” or “Validated Data Production”.
    • If you are uncertain of your level of participation, we recommend reaching out to your registry or EHR vendor now to get verification of your level of active participation.

“Are there any new measures for 2023?”

Yes, the Query of Prescription Drug Monitoring Program (PDMP) measure is now mandatory. There are exclusions for this new mandatory measure. We recommend reviewing to verify that you can either meet this measure (still a yes or no that one query was conducted in the reporting period), or that you qualify for an exclusion.

There is also a new alternate measure in the Health Information Exchange objective, called “Enabling Exchange under the Trusted Exchange Framework and Common Agreement (TEFCA)”. You do not need to report on this unless you are actively participating in this Health Information Exchange.

“Are there any changes to the scoring of measures in the MIPS PI category?”

Yes, because of changes to measures over the past few years, CMS has re-adjusted the points per measure. Our Mingle Health Promoting Interoperability Guide has a column showing the 2023 scoring for each measure.

If you have any MIPS Promoting Interoperability questions or need guidance related to filing for a PI hardship, please reach out to your Mingle consultant to discuss further.

Want to learn more about the MIPS program in 2023?

As MIPS becomes more difficult, it's crucial to have a plan in place. We've made a guide that provides an overview of 2023 MIPS requirements and changes to help you and your organization find success in the 2023 Performance Year.

Access the Guide
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