CMS Releases New MIPS Promoting Interoperability Guidance for 2021

The Centers for Medicare & Medicaid Services (CMS) recently released a wealth of new guidance and resources for MIPS Promoting Interoperability (PI) measures and program requirements for the 2021 reporting period. These changes are based on the IPPS (or inpatient) rule. However, the guidance released in the IPPS rule is usually mirrored in the outpatient rule, which should be released later this summer. As usual, there is a lot to go through. However, most requirements are being carried over from 2020 so only a handful of changes need to be noted by our readers (have no fear; we’ve already done the grunt work, so you don’t have to).

In this blog, we will take a look of some of the key changes for 2021, along with some requirements that will remain, for the PI program in the 2021 MIPS reporting period.

What is Changing for 2021

According to CMS, providers should note the following changes to the PI program for 2021:

• Modifying the name of the Support Electronic Referral Loops by Receiving and Incorporating Health Information measure, included in the Health Information Exchange (HIE) objective, to Support Electronic Referral Loops by Receiving and Reconciling Health Information.
• Increasing the number of electronic clinical quality measure (eCQMs) data reported from one self-selected quarter to two self-selected quarters of data (for hospitals only—to participate in MIPS, practices will still need to report eCQMs for a full year).

What is Staying in 2021

Based again on information from CMS, the following requirements will remain in 2021:

• Maintaining the ePrescribing objective’s Query of the Prescription Drug Monitoring Program (PDMP) measure as optional; it is still worth five bonus points.
• A minimum of any continuous, self-selected, 90-day electronic health record (EHR) reporting period.
• Participants must report on four objectives:

• Electronic Prescribing
• Health Information Exchange
• Provider to Patient Exchange
• Public Health and Clinical Data Exchange
• CMS will continue to implement a performance-based scoring methodology with scoring occurring for each of the individual measures.
• Submit a “Yes” to the following:
• Security Risk Analysis measure
• Prevention of Information Blocking Attestations
• ONC Direct Review Attestation

Certified Electronic Health Record Technology (CEHRT) Requirements for 2021

As a reminder, CMS has noted the following CEHRT requirements for 2021:

• Required use of (1) existing 2015 Edition certification criteria, (2) the 2015 Edition Cures Update criteria, or (3) a combination of the two, as finalized in the calendar year 2021 Physician Fee Schedule Final Rule (85 FR 84818 through 84828).
  • For more information about the 2015 Edition Cures Update, please review ONC’s 21^st Century Cures Act Final Rule. To check whether a health IT product has been certified to the 2015 Edition Cures Update criteria, visit the Certified Health IT Product List.
• CEHRT functionality must be in place by the first day of the EHR reporting period.
• EHR must be certified by ONC by the last day of the EHR reporting period.
• Must use the CEHRT functionality for the full EHR reporting period.

The Full Details

For readers who want to take a deep dive into the details of the entire 2021 MIPS reporting period, here is a list of resource links:

• 2021 Medicare Promoting Interoperability Program Requirements Webpage
• 2021 Medicare Promoting Interoperability Program Requirements Infographic
• 2021 Scoring Methodology Fact Sheet
• 2021 eCQM Reporting Requirements Table
• 2021 CEHRT Fact Sheet
• Security Risk Analysis Fact Sheet

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