Excerpted from “MIPS 2024, Part 2—What’s New With PI, Improvement Activities, and Cost" (EyeNet, February 2024), posted online ahead of print.
Do you rely on a third party, such as an EHR vendor or registry, to submit your MIPS data and attestations to CMS?
Currently, the agency allows four categories of third-party intermediary to do this:
- health IT vendors;
- qualified registries;
- qualified clinical data registries (QCDRs), such as the IRIS Registry; and,
- CMS-approved survey vendors (for the CAHPS for MIPS survey).
CMS has concerns with one category of third-party intermediary. However, the agency has noted that some health IT vendors have repeatedly provided it with MIPS data that are “inaccurate and unusable.” Consequently, 2024 is the last performance year health IT vendors can act as a third-party intermediary.
Will your EHR vendor be able to report MIPS for you in 2025? Starting with the 2025 performance year, an EHR vendor must successfully apply to be a qualified registry or a QCDR in order to attain the third-party intermediary status that would allow it to submit MIPS data on your behalf.
If EHR vendors don’t attain that status, CMS notes that they can still provide technology that would allow clinicians themselves to report MIPS data directly to CMS.
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