Promoting Interoperability / MIPS

Advis’ propriety strategic readiness assessment can help with Promoting Interoperability / MIPS.

To ensure readiness for  reporting, Advis is helping medical groups and health systems develop strategic plans that will maximize bonuses and minimize penalties under the 2015 Medicare Access and CHIP Reauthorization Act (MACRA), which created the Quality Payment Program (QPP), Merit-based Incentive Payment System (MIPS), and Alternative Payment Models (APM).

Strategic planning is essential to minimize current and fare future reimbursement penalties on Medicare Part B payments and maximize bonus payments. Selecting the appropriate participation method and quality measures for tracking/reporting is the first step to doing so.


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Effective Performance Reporting

To achieve bonus reimbursements and/or avoid any negative payment adjustments, providers are required to report based on  performance.

Performance will be measured across four  categories, including:

  • Quality
  • Technology
  • Improvement activities
  • Cost (Note: APMs are not measured on Cost) 

Above-average performances in one or both of these areas will likely lead to significant bonus payments in future years.


Advis’ proprietary strategic readiness assessment robustly models future state through a rigorous eight-step process:

  1. Determine which, if any, providers participate in an APM and what level of participation is currently reported.
  2. Review and assess performance to date (APM and MIPS).
  3. Review past and expected trends in quality metrics for past and future years.
  4. Assess how long-term strategic plans and subsequent changes to provider mixes may impact the overall adjustment score.
  5. Understand how the reporting mechanism will affect the measures selected and what the best reporting mechanism is for the group.
  6. Prepare a financial projection based on previous performance.
  7. Determine if the patient population is likely to receive a Complex Patient Bonus.
  8. Analyze whether participation in a “virtual group” may be beneficial in future years, pending CMS proposals.

The result is a multi-year approach which ensures providers avoid a negative payment adjustment and establish a strong position to receive future bonuses.

Advis is available to perform a strategic readiness assessment and prepare multi-year strategic plans to help providers avoid a negative payment adjustment and establish a strong position to receive future bonuses. Contact us today to make sure you’re ready and it won’t affect your bottom line.

MPIP & MIPS Updates for 2022

CMS has multiple programs in place to reward providers with payment adjustment increases (and potentially downwardly adjust payments for providers who do not meet the standards) for the quality of care they provide to Medicare patients. Two of those programs, the Medicare Promoting Interoperability Program (MPIP) and the Merit-based Incentive Program (MIPS), use data collected throughout the calendar year to measure items such as quality and cost of patient care, improvements made to the clinical care processes, patient engagement with the provider, and meaningful use of certified electronic health record technology (CEHRT). Reporting is then completed electronically during the first quarter of the year following data collection, with the reported data then used to adjust payments for the next year. Calendar Year 2022 data will be reported in the first quarter of 2023 and that data will be used to adjust the payments for 2024.

Eligible hospitals and critical access hospitals (CAH) report data to MPIP, while MIPS is for eligible clinicians. Both programs require eligible providers to report the collected data if they meet the eligibility requirements, and both can result in a negative Medicare payment adjustment if ignored.

Below is more information on each of these programs.


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Medicare Promoting Interoperability Program (MPIP)

What are the eligibility requirements?

“Subsection (d)” hospitals in the 50 states, DC, and Puerto Rico that are paid under the Inpatient Prospective Payment System (IPPS); CAHs; and Medicare Advantage (MA-Affiliated) Hospitals are eligible to participate.

What data is submitted?

Eligible hospitals and CAHs must:

  1. Provide proof of use of an electronic health records system that meets CEHRT requirements;
  2. Report on four objectives and their associated measures:
    1. Electronic Prescribing
    2. Health Information Exchange
    3. Provider to Patient Exchange
    4. Public Health and Clinical Data Exchange; and
  3. Report on three electronic clinical quality measures (eCQMs) and the Safe Use of Opioids – Concurrent Prescribing eCQM using three self-selected quarters of data.

How are payment adjustments applied?

If an eligible hospital does not demonstrate meaningful use, the payment adjustment is applied as a reduction to the applicable percentage increase to the Inpatient Perspective Payment System payment rate for one year.

If a CAH does not demonstrate meaningful use, its Medicare reimbursement will be reduced from 101 percent of its reasonable costs to 100 percent for that year.

What’s new 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 in order to meet the CEHRT definition.
  3. The CEHRT functionality must be in place by the first day of the EHR reporting period and 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.

Merit-based Incentive Payment System (MIPS)

What are the eligibility requirements?

Eligible clinician types include: Physicians (includes doctors of medicine, osteopathy, dental surgery, dental medicine, podiatric medicine, and optometry; osteopathic practitioners; and chiropractors (with respect to certain specified treatment, a Doctor of Chiropractic legally authorized to practice by a State in which he/she performs this function)), Physician Assistants, Nurse Practitioners, Clinical Nurse Specialists, Certified Registered Nurse Anesthetists, Clinical Psychologists, Physical Therapists, Occupational Therapists, Qualified Speech-Language Pathologists, Qualified Audiologists, Registered Dietitians or Nutrition Professionals, and new for 2022, Clinical Social Workers and Certified Nurse Midwives.

Clinicians must exceed the low-volume threshold to be required to participate in MIPS. A clinician exceeds the low-volume threshold if he or she meets all the following criteria:

  1. Bill more than $90,000 a year in allowed charges for covered professional services; AND
  2. See more than 200 Medicare Part B beneficiaries; AND
  3. Provide more than 200 covered professional services to Part B patients.

Participation status can be checked on the CMS Quality Payment Program website.

What data is submitted?

MIPS is based on four performance categories: Quality, Cost, Improvement Activities, and Promoting Interoperability. Each category is weighted and has a set of measures, objectives, or improvement activities that must be completed/reported on to earn points. Data may be submitted by individual clinicians, groups, or virtual groups via the traditional MIPS or Alternative Payment Model (APM) MIPS pathways. The number of points received (out of 100 possible) establishes the performance threshold, which determines the type of payment adjustment – positive, negative, or neutral.

How are payment adjustment applied?

Clinicians receive either an upward or downward payment adjustment for Part B covered professional services based on the evaluation of performance across different performance categories.

What’s new for 2022?

  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 the 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.

Both MPIP and MIPS offer hardship exceptions on a case-by-case basis for providers who are unable to meet the requirements of the program, but the deadlines are fast approaching. Applications for MPIP hardship exceptions are due by September 1, 2022, and applications for MIPS hardship exceptions are due by December 31, 2022.

The team at Advis can help you or your organization navigate the intricacies of these programs and maximize your reimbursement amounts. For assistance with MPIP or MIPS, please contact Advis online, or by calling 708.478.7030.