MIPS Compliant EHR Software

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MIPS, formally known as the Merit-Based Incentive Payment System, is a central component of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The regulations it sets have upended the way behavioral health providers can qualify to receive Medicare reimbursement.

If you want to avoid penalties, you need to understand what standards your practice is expected to meet. Securing a compliant EHR is one of the fundamental improvements you can make to get MIPS to work for you. Here is a brief overview of MIPS requirements to help you pick the right software.

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Quick MIPS Facts

Official title: Merit-Based Incentive Payment System
Year enacted: 2017
Aliases: MIPS
Most recent update to MIPS: 2019
MIPS compliance and enforcement: Centers for Medicare & Medicaid Services (CMS)

What Is MIPS?

The Quality Payment Program (QPP) is a portion of MACRA designed to enhance value-based care payment. It is a natural outgrowth of the Health Information Technology for Economic and Clinical Health Act (HITECH) of 2009, which encouraged the use of EHRs. Under the QPP, healthcare providers receive incentives for offering better quality and value to patients. MIPS is one of the two pathways providers can take to link payments to quality of care, with the other pathway being Alternative Payment Models (APM).

Providers started reporting performance data for QPP reimbursement in 2017. Data collected affects payment adjustments two years after collection, so 2017 data was used to calculate 2019 payment adjustments, 2019 data will determine 2021 payment adjustments, and so on.

There are four performance categories MIPS uses to score healthcare providers:

Quality: 45% of final score
Cost: 15% of final score
Improvement activities: 15% of final score
Promoting interoperability: 25% of final score

Healthcare providers can earn up to a total of 100 points across all of these categories, though each category is weighted differently, and the weight may change year to year. For example, in 2018 cost was only 10% of the score, while quality was 50%.

What Patient Rights are Protected Under MIPS?

MIPS has a component called Advancing Care Information (ACI), which is a category that replaces the EHR Incentive Program more commonly known as "meaningful use." This component represents the intersection with HIPAA compliance, which requires healthcare providers to secure protected health information (PHI). Providers must conduct risk assessments to find gaps and vulnerabilities in security that could lead to breaches of protected information, such as:

Names
Addresses
Phone numbers
Social Security numbers
Vehicle identifiers
Biometric identifiers

If any gaps in security are found, HIPAA requires that the provider makes formal plans to correct them.

Fines and Penalties for Noncompliance

MIPS reporting is voluntary and part of an incentive program, so there is no enforcing body to pursue MIPS violations. While there is an incentive for successfully participating in the program, there is also encouragement in the form of reimbursement penalties from CMS.

The incentives and penalties vary by year:

Performance Year	Payment Adjustment Year	Maximum MIPS Penalty	Maximum MIPS Incentive
2017	2019	-4%	+4%
2018	2020	-5%	+5%
2019	2021	-7%	+7%
2020	2022	-9%	+9%
2021	2023	-9%	+9%
2022	2024	-9%	+9%

Succeeding With MIPS

For mental and behavioral healthcare providers to avoid penalties and earn bonuses, there are multiple steps to take in all four performance categories. The cost category is of low impact and is not easily controlled. The other three measures can be positively influenced by fulfilling the basic requirements.

1. Quality: 45% of Score

Clinicians must report six measures and one outcome, or a single high-priority measure for 12 months. Reporting at least one case can earn one to three points. If you want to earn more than three points, you must report a minimum of 60% of cases.

2. Improvement Activities: 15% of Score

There are a variety of differently weighted improvement activities you can choose to complete this MIPS requirement. You must complete up to two high-weighted activities or four medium-weighted activities. Exceptions include groups with 15 or fewer participants and those in rural areas. These cases can fulfill the requirement with one high-weighted or two medium-weighted activities.

3. Promoting Interoperability: 25% of Score

Starting in 2019, certified EHR technology is required to participate in the promoting interoperability category.

Interoperability has nine required components:

e-Prescribing
Electronic health information access for patients
Sending health information to support electronic referral loops
Receiving health information
Immunization registry reporting
Syndromic surveillance reporting
Electronic case reporting
Public health registry reporting
Clinical data registry reporting

Frequently Asked Questions About MIPS

Are there any exemptions under MIPS?

How is Advancing Care Information different from the EHR Incentive Program?

Can I participate without an EHR?

What is the QPP timeline?

How does promoting interoperability differ from meaningful use?

MIPS Compliance and EHRs

Now that clinical psychologists have joined psychiatrists in eligibility for MIPS participation, choosing a compliant EHR is more critical than ever — especially if you want to reap the benefits of the incentive program and avoid costly penalties. The most crucial EHR compliance feature to look for is ONC certification. Without it, you won't be eligible for one of the four categories, which can affect your score dramatically.

The other essential requirement is a HIPAA-compliant EHR software. Security risk analysis is required if you want to avoid penalties, and a non-compliant software will greatly increase the work you have to do to become compliant.

Maximize MIPS Incentives With ICANotes

Improving the quality of your documentation is an essential part of increasing your quality score. Improving documentation with a compliant EHR technology will make it easier to get the maximum score on promoting interoperability.

ICANotes is the most clinically robust EHR software designed by behavioral health experts for behavioral health professionals. Our dedication to compliance in the rapidly shifting healthcare industry means we are constantly updating our platform to accommodate new rules and regulations. To learn more about how ICANotes can improve your quality of care while reducing the time you spend on documentation, request a free trial of the software.

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