MIPS reporting is difficult for pain practices because the relevant documentation, procedure workflows, prescribing, billing, and quality reporting often live in separate systems. An EHR can support compliance, but no product guarantees it on its own. “MIPS compliant” is not a permanent designation for any technology, and requirements change by performance year, so practices should verify current rules directly through CMS.

What Are MACRA and MIPS?

MACRA established the Quality Payment Program, which includes the Merit-based Incentive Payment System, or MIPS. MIPS scores eligible clinicians on performance during a given year, which then affects Medicare payment in a later payment year. Clinicians can participate individually, as a group, as a virtual group, through an MVP, or through an APM. Eligibility is determined by NPI and practice association, and it can vary by TIN/NPI combination. Check current status using the official QPP eligibility tool rather than relying on a general rule.

Does Your Practice Have to Participate?

Participation depends on clinician type, Medicare enrollment status, the low-volume threshold, and Qualifying APM Participant status, along with any special statuses or exceptions that apply. CMS determines eligibility using multiple factors and provides performance-year-specific results through QPP. There is no single universal answer for whether a pain practice must participate.

The Four MIPS Performance Categories

Quality. Measure data should be captured as part of normal documentation, not as a separate task. Each measure has its own numerator, denominator, exclusion, and exception logic, along with data completeness requirements and benchmarks. Case eligibility should be monitored throughout the year rather than reviewed only at the end.

Promoting Interoperability. This category depends on certified EHR technology and includes electronic prescribing, health information exchange, patient electronic access, and, where applicable, public health and clinical data exchange. A security risk analysis and its required attestations are part of this category as well.

Improvement Activities. Practices select activities relevant to their workflows and must maintain evidence beyond simply checking a box. Track the duration and completion of each activity and connect it to work the clinic is already doing.

Cost. CMS calculates this category from claims data, not from the EHR directly. Documentation, referral patterns, site of service, avoidable utilization, and care coordination all influence cost performance, even though the EHR does not control the calculation itself.

Pain Management Workflows That Affect MIPS Performance

Several workflows common to interventional pain practices intersect with MIPS categories, including standardized pain and functional assessments, longitudinal outcome tracking, medication reconciliation, opioid risk screening, PDMP access, controlled-substance agreements, urine drug-screen documentation, imaging and referral coordination, procedure documentation, post-procedure follow-up, and patient portal access. Not every one of these workflows corresponds to a current MIPS measure, so confirm applicability against current measure specifications rather than assuming.

How an EHR Supports MIPS Compliance

Well-suited MIPS reporting software helps by capturing structured data during the visit, prompting for measure-specific documentation, and running automated eligibility checks.Real-time performance dashboards and patient-level gap lists let staff address missing data before a deadline rather than after. Exclusion and exception tracking, audit trails, electronic quality-measure calculation, and evidence retention all reduce the manual reconciliation work that otherwise falls on staff at year-end.

Certified EHR Technology and Reporting

ONC certification applies to a specific product and version, not to a practice’s entire configured technology stack. Confirm the exact product name and version in use, and verify that the certification covers the criteria required for the applicable performance year. For 2026, CMS technical guidance states that a CMS EHR Certification ID is required for the MIPS Quality performance category. Reporting periods and requirements vary by category and participation pathway, so check details against the current CMS QRDA III Implementation Guide and other current CMS materials rather than assuming last year’s rules still apply.

Questions to Ask an EHR Vendor About MIPS

1. Is the exact product version ONC certified?
2. Which MIPS measures can it calculate?
3. Does it support measures relevant to pain management workflows?
4. Can staff view performance before the reporting deadline?
5. How are measure specifications updated?
6. Can users drill down to patients missing required data?
7. Which reporting methods are supported?
8. Are MIPS tools included or priced separately?
9. Who validates calculated performance?
10. What evidence is retained for an audit?

Common MIPS Compliance Mistakes

• Waiting until year-end to review performance
• Assuming ONC certification guarantees compliance
• Documenting required information only in free-text notes
• Choosing measures without checking case volume
• Failing to verify exclusions
• Relying on a dashboard without validating source data
• Ignoring security risk analysis requirements
• Losing supporting evidence for improvement activities

A Year-Round MIPS Workflow

• Before the performance year: Verify eligibility, reporting pathway, technology, and measures.
• Early in the year: Configure templates and establish baseline performance.
• Monthly: Review missing data and measure eligibility.
• Quarterly: Validate samples against patient charts and claims.
• Before submission: Reconcile results, exclusions, attestations, and supporting evidence.
• After submission: Retain confirmation records and prepare for feedback.

Frequently Asked Questions

Is there such a thing as a MIPS-certified EHR? No. EHRs can hold ONC certification, but MIPS compliance depends on how the certified technology is configured and used, not on the product alone.

Does an ONC-certified EHR automatically make a clinic compliant? No. Certification is one requirement among several. The practice still needs correct configuration, complete documentation, and validated reporting.

Can a small pain practice be excluded from MIPS? Some practices fall below the low-volume threshold or otherwise qualify for an exclusion, but eligibility is determined by CMS using multiple factors and should be checked through QPP rather than assumed.

Does MIPS require a full year of reporting? Reporting periods vary by performance category. Check current requirements for each category rather than assuming a single period applies across all of them.

Can an EHR submit MIPS data directly? Many EHRs support direct submission or export to a qualified registry, but supported submission methods vary by vendor and should be confirmed directly.

What happens if the EHR changes during the performance year? Practices changing systems mid-year need a plan for migrating structured data and reconciling performance across both systems to avoid gaps in reporting.

How often should a practice review its MIPS dashboard? Monthly review is a reasonable minimum, with more frequent checks as the submission deadline approaches.

Choosing the Right Approach

Successful MIPS participation depends on the combination of suitable technology, correct configuration, reliable workflows, staff execution, and ongoing validation. No EHR replaces that combination on its own.