Excerpted from “MIPS—What’s New for 2022, Part 1: Scoring, Bonuses, and Penalties” (EyeNet, January 2022). Also see, EyeNet’s MIPS Manual 2022: A Primer and Reference.
Promoting interoperability (PI) is MIPS’ EHR-based performance category. Much about PI stays the same for performance year 2022, but there have been some changes, including the following.
The PI exception for small practices is now automatic. If you are in a small practice, which CMS defines as a practice with 15 or fewer “eligible clinicians,” you can be excused from participating in the PI performance category. In prior performance years, you were only eligible for this exception if you applied for it. For the 2022 performance year, this exception is automatic: If you are in a small practice and do not report on any PI measures, CMS will grant you a PI exception. However, if you do any PI reporting, CMS will assign you a PI score and factor that score into your MIPS final score. (Note: In past years, practices that had entered a date range for their PI performance period on the CMS website were denied the PI exception, even though they hadn’t submitted any PI data.)
Must make a SAFER attestation. The nine Safety Assurance Factors for EHR Resilience (SAFER) guides are intended to help health care organizations conduct self-assessments. The Higher Priority Practices guide provides an overview of EHR safety concerns, which are discussed in more detail in the other eight guides:
- Organizational Responsibilities
- Contingency Planning
- System Configuration
- System Interfaces
- Patient Identification
- Computerized Provider Order Entry With Decision Support
- Test Results Reporting With Follow-Up
- Clinician Communication
CMS wants practices to conduct a self-assessment of EHR resiliency based on these SAFER guides, starting with the High Priority Practices guide. At time of press, CMS hadn't published the specific requirements for this assessment. (For more information on these guides, see www.healthit.gov/topic/safety/safer-guides.)
CMS has streamlined the Prevention of Information Blocking attestation. This attestation reflects a CMS concern that practices might “knowingly and willfully” take steps to limit the compatibility or interoperability of CEHRT. For the 2022 performance year, you have to attest “yes” to only one statement, down from three previously.
New reporting requirements for PI’s Public Health and Clinical Data Exchange objective. As in 2021, this objective includes five PI measures:
- Immunization Registry Reporting
- Electronic Case Reporting
- Public Health Registry Reporting
- Clinical Data Registry Reporting
- Syndromic Surveillance Reporting
In 2021, you could meet the requirements of this objective by performing (or meeting the exclusion criteria) for any two of those five measures. In light of the COVID-19 pandemic, CMS has changed those requirements for the 2022 performance year. You must now perform (or claim an exclusion for) two specific measures—1) Immunization Registry Reporting and 2) Electronic Case Reporting—and you can earn PI bonus points for performing a third measure. (Note: Ophthalmology practices have often been able to claim exclusions for the Immunization Registry Reporting measure and the Electronic Case Reporting measure, depending on state requirements.)
A new exclusion for the Electronic Case Reporting measure. CMS has added a fourth exclusion for the Electronic Case Reporting measure. This applies if you are using a CEHRT that hasn’t been certified to the electronic case reporting criterion prior to the start of your PI performance period.
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