This content is excerpted from “MIPS 2023, Part 1” (EyeNet, January 2023). EyeNet’s MIPS content, including its MIPS 2023 supplement, is being published online ahead of print as it becomes available.
Promoting interoperability (PI) is the MIPS performance category that focuses on your use of EHR, which—new for 2023—must have 2015-edition Cures Update certification.
PI Is Organized Around Four Objectives
As in previous years, the PI performance category is organized around four objectives:
The e-Prescribing objective. This objective involves reporting on (or claiming the exclusion for) the e-Prescribing measure and the Query of Prescription Drug Monitoring Program (PDMP) measure.
The Query of PDMP measure is now required. In 2022, the Query of PDMP measure was an optional bonus measure. It involved using data from CEHRT to conduct a query of PDMP for prescription drug history relating to a Schedule II opioid before prescribing such a drug to a patient. For 2023 it is a required measure, and its scope has been expanded to include Schedule III and IV drugs.
You can claim an exclusion from the Query of PDMP measure in the following circumstances: 1) if you write fewer than 100 permissible prescriptions during the performance period and/or 2) if you are unable to prescribe Schedule II, III, and IV drugs in accordance with applicable law and/or—for 2023 only—3) if querying a PDMP “would impose an excessive workflow or cost burden” prior to the start of your PI performance period. If you claim one of these exclusions, CMS will reassign the 10 points associated with this measure to the e-Prescribing measure.
The Health Information Exchange (HIE) objective. In 2022, there were two options for fulfilling the requirements of the HIE objective: you could either 1) report on (or claim exclusions for) the two electronic referral loop measures or 2) report on the HIE Bi-Directional Exchange measure. For 2023, CMS has added another option: 3) report on the Enabling Exchange Under the Trusted Exchange Framework and Common Agreement (TEFCA) measure.
What is TEFCA? TEFCA features a technical infrastructure model that is intended to provide a minimum level of interoperability, thus helping users to exchange clinical information securely. Qualified Health Information Networks (QHINs) are being encouraged to sign an agreement that promotes the use of TEFCA.
The new TEFCA measure. This Enabling Exchange Under the TEFCA measure involves connecting directly to a QHIN (or connecting to an entity that connects to a QHIN) and using CEHRT to support secure, bidirectional exchange of patient information in accordance with TEFCA.
The Provider to Patient Exchange objective. This objective is largely unchanged.
The Public Health and Clinical Data Exchange objective. The five measures in this objective each involve active engagement with a public health agency (PHA) or a clinical data registry—though exclusions are available if, for example, you don’t treat any diseases that your local PHA collects data on.
Previous definition of active engagement. Under the EHR meaningful use program that preceded MIPS, CMS defined active engagement as moving toward sending production data or actually sending production data, with production data defined as data generated through clinical processes involving patient care. Under MIPS, CMS established three options for demonstrating active engagement: 1) completing a registration to submit data, 2) testing and validating the electronic submission of data, and 3) electronically submitting production data.
New definition of active engagement. In 2023, you have two options for demonstrating active engagement: 1) preproduction and validation (this combines the old options 1 and 2) and 2) validated data production (which replaces the old option 3).
You must submit your level of engagement. When reporting the Public Health and Clinical Data Exchange measures, you must attest that you are actively engaged with a PHA or clinical data registry and—new for 2023—you must also attest your level of engagement (either validated data production or preproduction and validation).
Change in scoring. In 2023, the points you can earn for each objective are as follows:
- Electronic Prescribing: 20 points (in 2022, it was 10 points plus 10 bonus points)
- HIE: 30 points (down from 40 points in 2022)
- Provider to Patient Exchange: 25 points (down from 40 points in 2022)
- Public Health and Clinical Data Exchange: 25 points plus, if you integrate your EHR system with the IRIS Registry, 5 bonus points (up from 10 points plus 5 bonus points in 2022)
As in previous years, if you are excluded from all the measures in an objective, the points for that objective may be reassigned to another objective.
Changes in the PI automatic exception policy. Certain types of clinicians are automatically excepted from PI. However, as of 2023, this PI automatic exception no longer applies to nurse practitioners, physician assistants, clinical nurse specialists, or certified registered nurse anesthetists. It continues to apply to several other clinician types, but none of them are likely to be employed in an ophthalmology practice. (Note: There is still a PI automatic exception for clinicians in small practices, regardless of clinician type, provided they don’t report any PI data.)
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