Guide to MIPS Promoting Interoperability Requirements for 2024

The Merit-based Incentive Payment System (MIPS) is a program by the Centers for Medicare & Medicaid Services (CMS) that adjusts Medicare Part B payments based on specific performance metrics. One of the most important of these metrics is the MIPS Promoting Interoperability performance category, which evaluates the use of Certified Electronic Health Record Technology (CEHRT).

CMS implemented the MIPS Promoting Interoperability measures as a strategy for enhancing healthcare efficiency and the quality of patient care by encouraging seamless exchange of data across ecosystems— payers, providers, pharmacies, and other key organizations who play a role in the patient journey.

Success in meeting MIPS interoperability requirements directly impacts an organization’s overall MIPS score and can lead to adjustments in their Medicare reimbursements. Consequently, it’s important for all healthcare providers to understand and strategize in this area.

This guide will provide an overview of the MIPS Promoting Interoperability Program at large and detail what you need to know about its most recent 2024 updates.

Key Takeaways:

• MIPS Promoting Interoperability performance category accounts for 25% of the total MIPs score.
• New updates for MIPS interoperability requirements in 2024 include updated CEHRT definitions, an extended performance evaluation period, and an introduction to SAFER guidelines.
• It’s critical for healthcare organizations to act proactively and implement the right tools and processes as early as possible to facilitate MIPS compliance.

MIPS Promoting Interoperability Category: An Overview

The MIPS Promoting Interoperability requirements are fundamentally designed to advance healthcare delivery by improving accessibility and the secure, efficient exchange of health information. This initiative ensures that healthcare providers make optimal use of CEHRT to enhance patient care quality and outcomes as well as system interoperability across the healthcare spectrum.

This category accounts for 25% of the total MIPS score in 2024, making it a critical focus for participating healthcare providers.

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It emphasizes four important areas of focus:

1. e-Prescribing: The use of CEHRT to electronically send prescriptions to pharmacies, improving accuracy, efficiency, and thus overall patient safety when taking medications
2. Health Information Exchange (HIE): The electronic movement of health information among organizations according to nationally recognized standards, crucial for coordinating patient care across different settings.
3. Provider to Patient Exchange: Ensures that providers give patients electronic easy access to their health information, improving patient engagement and self-management
4. Public Health and Clinical Data Exchange: Requires providers to report health data to public health agencies, promoting the use of data in managing population health and enhancing crisis response capabilities

Within each of these measures are 6-7 required measures as well as specific attestations. For example, the Health Information Exchange focus area includes measures for supporting electronic referral loops, and the Public Health and Clinic Data Exchange focus area measures immunization registry reporting.

You can find detailed information on each specific measure (and in some cases, exclusions) on the fact sheets available for download on this CMS resource page.

It’s also important to note that organizations can earn bonus points in each area. These are categorized in many ways (also outlined on the fact sheets linked above). Some examples include YOY improvement, medical complexity of patients, and using CEHRT to report certain public health data.

What’s New in 2024 for MIPS Promoting Interoperability

As healthcare continues to evolve, so do MIPS interoperability requirements. In 2024, significant updates have been made to refine the integration and usage of electronic health records, ensuring providers meet the highest standards of care efficiency and data security. Here’s what healthcare providers need to know about the key changes for this year:

Updated CEHRT Definitions

The definition of CEHRT has been updated to align more closely with the latest standards from the Office of the National Coordinator for Health Information Technology (ONC). These changes ensure that the technologies used are fully capable of supporting new interoperability standards and facilitate better data exchange and patient access to health information.

For providers, this means reviewing and potentially upgrading their EHR systems to comply with the new CEHRT requirements to avoid penalties and maximize their MIPS score.

Extended Performance Period

Beginning in 2024, the performance period for reporting MIPS Promoting Interoperability measures has been extended to a minimum of 180 continuous days. This change from shorter reporting periods in previous years means that providers will need to maintain consistent, reliable health record management practices over a longer duration.

This extension aims to provide a more comprehensive assessment of a provider’s use of EHR technology and to encourage sustained performance improvement throughout the year.

Discontinuation of Automatic Reweighting

Previously, certain professional groups such as nurse practitioners, physician assistants, and clinical nurse specialists were eligible for automatic reweighting in the Promoting Interoperability category, exempting them from penalties due to non-participation.

Starting in 2024, this automatic reweighting will be discontinued and these groups will also be required to actively participate and report in this category.

Modification to the PDMP Query Measure Exclusion

Exclusion criteria for the Query of Prescription Drug Monitoring Program (PDMP) measure have been refined. In 2024, any MIPS-eligible clinician who does not electronically prescribe Schedule II opioids or Schedule III or IV drugs during the performance period is excluded from this measure.

This is intended to align the measure more closely with the clinician’s scope of practice and prescribing patterns.

Introduction of SAFER Guide Measure Requirement

A new mandatory measure has been implemented requiring a “yes” response for the Safety Assurance Factors for Electronic Health Record Resilience (SAFER) Guide. This measure emphasizes the importance of adhering to best practices for EHR safety and cybersecurity.

Key Steps to Meeting MIPS Interoperability Requirements

Consistently meeting MIPS interoperability requirements and achieving the best score possible requires a focused and methodical approach. CMS outlines the process in 5 key steps:

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Step 1: Understand Your Reporting Requirements

Take time to familiarize yourself with the changes in reweighting rules and reporting exemptions. Review your eligibility and any potential reweighting opportunities. Confirm if your organization falls under any special status categories that exempt them from data reporting, and if not, understand the full extent of your reporting obligations.

Step 2: Review the CEHRT Requirements

Be sure your systems align with the updated CEHRT criteria. This includes having an EHR system that meets the latest ONC standards by the first day of your selected 180-day performance period. Verifying these requirements early is crucial to ensure compliance throughout the reporting period.

Step 3: Navigating the Measures and Reporting Periods

Select appropriate measures to report on from the four focus areas: e-Prescribing, Health Information Exchange, Provider to Patient Exchange, and Public Health and Clinical Data Exchange. Manage these measures consistently across the newly extended 180-day reporting period. Understand the measures’ specifics, including any exclusions that might apply, to ensure accurate reporting.

Step 4: Complete Required Attestations

2024 sees the introduction of mandatory attestations such as the Safety Assurance Factors for EHR Resilience (SAFER) Guide, where a “yes” response is now required. Conduct an annual self-assessment using the SAFER Guides to ensure compliance. Review all required attestations and ensure you’re prepared to answer appropriately.

Step 5: Data Submission Strategies

Accurately and timely data submission during the designated period (January 2, 2025, to March 31, 2025) is vital. Prepare your data submissions according to the MIPS protocols, ensuring data reflects the CEHRT criteria. Effective submission strategies will prevent penalties and optimize potential incentives.

How Gaine Can Help

Gaine’s Coperer Health Data Management Platform (HDMP) is a comprehensive, ecosystem-wide tool built to help healthcare organizations meet complex requirements like MIPS Promoting Interoperability measures. By leveraging advanced Coperer capabilities, organizations can effectively navigate updated MIPS criteria as it evolves and be confident in their data accuracy, exchange processes, and compliance.

Learn more here about how Coperer can help you maximize data ROI and meet compliance goals.