Medicare Compliance & Reimbursement

Understand how they vary and impact quality incentives.

If differentiating between Medicare’s Promoting Interoperability (PI) Programs and its Merit-Based Incentive Payment System (MIPS) PI performance category has you flummoxed, you’re in good company. When Medicare opted to use the same moniker for two completely separate but similar programs, providers were confused. There are a few clues, however, that will help you determine which PI requirements affect your practice or organization.

History: In an effort to boost EHR usage and promote data sharing among healthcare providers, the Centers for Medicare & Medicaid Services (CMS) created the Medicare and Medicaid EHR Incentive Programs, nicknamed Meaningful Use (MU), in 2011. With the establishment of MU, the agency encouraged providers to “adopt, implement, upgrade, and demonstrate meaningful use of certified EHR technology (CEHRT),” notes CMS guidance. But despite the best intentions, the program had mixed reviews, uneven success, and so-so adoption.

Next: However, in 2015, MACRA was signed into law, and the legislation created a separate program — the Quality Payment Program (QPP) — specifically for Medicare-eligible clinicians to attest and submit their quality measures. “These eligible clinicians who had previously participated in the EHR Incentive Programs” began participating in MIPS, “which is one of two ways to participate in [the] QPP,” notes CMS guidance. Originally, the MIPS health IT performance category was named Advancing Care Information (ACI).

Latest change: In 2018, the feds devised a revamp of both MU and the ACI performance category to cut providers’ administrative burdens while tying the IT and EHR requirements with other quality initiatives. CMS rebranded MU as PI Programs while simultaneously changing ACI to the MIPS PI performance category. And with these name changes, much confusion has ensued, creating issues for both CMS and attesting providers, agency guidance suggests.

Pocket this breakdown on the various nuances and differences between the Medicare PI Programs and MIPS PI performance category for calendar year (CY) 2021 garnered from CMS guidance:

Resources: Find more detailed information on the Medicare PI Programs at www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms and review PI performance category data and guidance at https://qpp.cms.gov/mips/promoting-interoperability.