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There are multiple changes and updates to the MIPS Promoting Interoperability category in 2023. On this page, we’ll outline everything MIPS participants need to know about PI to increase their chances of success in the coming year.
The MIPS Promoting Interoperability category is how CMS encourages the electronic exchange of health information using certified health record technology (CEHRT) for MIPS participants. Utilizing certified technology can increase patient access to health information, ease the exchange of information across the healthcare system, and allow for the systematic collection and analysis of healthcare data.
As a MIPS Participant, you’re required to use a certified EHR to participate in this category, and you’re required to submit data collected during the Performance Year for Promoting Interoperability measures. In 2023, Promoting Interoperability will represent 25% of your final MIPS score.
Now that we’ve had a chance to review the PI category let’s look at the changes to the category in 2023.
CMS has ended Automatic Reweighting for certain types of Clinicians in the 2023 Final Rule. Nurse Practitioners, Physician Assistants, Certified Registered Nurse Anesthetists, and Certified Nurse Specialists will no longer qualify for Automatic Reweighting in the Promoting Interoperability category.
For 2023, if you are one of these provider types and do not submit data in this category, and if you don’t have another special status that would allow re-weighting, the Promoting Interoperability’s contribution to your final MIPS score will not be redistributed to another category.
Clinicians in any of these groups will need to plan on collecting and submitting PI data for 2023.
There have been changes to the Engagement Levels of the Public Health and Clinical Data Exchange Objective in the 2023 Final Rule.
As a quick reminder, CMS defines “Active Engagement” to mean that you, a MIPS eligible clinician, are moving toward sending “production data” to a public health agency or clinical data registry or are currently sending production data to these entities.
Previously, there were three levels of Active Engagement. The three levels were:
After the 2023 Final Rule, there will only be two levels of Active Engagement:
Along with the change in levels of Active Engagement, CMS has also ruled that starting in the 2024 Performance Year, you can only be in the “Pre-Production and Validation” level of active engagement for one reporting period (one calendar year).
In previous years, the “Query of Prescription Drug Monitoring Program (PDMP)” measure was not a requirement for MIPS participants. CMS has changed this in the 2023 Final Rule, and this measure is now required.
CMS has also updated the Query of PDMP measure specifications:
CMS has created a new HIE measure in the 2023 Final Rule called “Participation in the Trusted Exchange Framework and Common Agreement (TEFCA).”
For the unfamiliar, the TEFCA framework was created by The Office of the National Coordinator for Health Information Technology (ONC) to:
“…establish a universal floor for interoperability across the country. The Common Agreement will establish the infrastructure model and governing approach for users in different networks to securely share basic clinical information with each other—all under commonly agreed-to expectations and rules, and regardless of which network they happen to be in.”
In the 2023 Final Rule, CMS encourages providers to increase interoperability by participating in the TEFCA framework. This is similar to the existing HIE Bi-directional exchange measure in that you get full points for this objective, if you meet the measure. You can contact your EHR vendor to determine if you qualify.
This measure is now in the inventory of HIE measures, so MIPS participants have a choice between four measures to fulfill the HIE requirements in the Promoting Interoperability category.
CMS also made a point in the 2023 Final Rule to clarify that MIPS participants are responsible for sharing information when laws and regulations require it. You can read more about CMS and ONC’s rules, resources, and responses to information blocking on the ONC Website >>
The 2023 Final Rule also contains scoring changes for the Promoting Interoperability category. You can find a table with the scoring methodology CMS outlined in the 2023 Final Rule below:
Have additional questions or concerns about the MIPS Improvement Activities Category in 2023? Get in touch with one of our experts today to learn more about MIPS, understand how you can improve your organization’s performance, and set yourself up for success in the coming years.