CMS recently hosted webinars to present 2022 guidelines for two of its incentive programs: Medicare Promoting Interoperability Program (MPIP) (formerly the Medicare and Medicaid EHR Incentive Program) and the Merit-based Incentive Program (MIPS). Below is a summary of the main updates for 2022.


  1. The EHR reporting period for new and returning participants attesting to CMS is a minimum of any continuous, self-selected, 90-day period. Eligible hospitals and CAHs must successfully attest to avoid a downward Medicare payment adjustment.
  2. To be considered a meaningful user and avoid a downward payment adjustment, eligible hospitals and CAHs may use (1) existing 2015 Edition certification criteria, (2) the 2015 Edition Cures Update criteria, or (3) a combination of the two to meet the CEHRT definition.
  3. The CEHRT functionality must be in place by the first day of the EHR reporting period. The product must be certified by the last day of the EHR reporting period. The eligible hospital or CAH must be using their selected version’s functionality for the full EHR reporting period.
  4. Adoption of the Health Information Exchange Bi-Directional Exchange measure as an alternative to the two existing measures under the Health Information Exchange Objective.
  5. Required reporting on four of the Public Health and Clinical Data Exchange Objective measures: Syndromic Surveillance Reporting; Immunization Registry Reporting; Electronic Case Reporting; and Electronic Reportable Laboratory Result Reporting.


  1. The performance threshold for a positive adjustment has been increased to 75.01 points. Negative payment adjustments will occur for any score below 75. If a clinician scores exactly 75 points, the payment adjustment is neutral (0%).
  2. For the Public Health and Clinical Data Exchange objective under the Promoting Interoperability category, Clinicians are required to report on 1) Immunization Registry Reporting, and 2) Electronic Case Reporting measures.
  3. MIPS Value Pathways (MVPs) are a subset of measures and activities, established through rulemaking, that can be used to meet MIPS reporting requirements beginning in the 2023 performance year.

The recording of the webinar and accompanying slides for MPIP may be found here. The recording and slides for MIPS will be posted here within the next two weeks.

For additional information about MPIP and MIPS, visit our website or call (708) 478-7030.

Published: April 28, 2022