Why Eligible Clinicians Need a Certified EHR to Report for MIPS, and the Implications of Not Using One
The Merit-based Incentive Payment System (MIPS) was introduced under the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015. This system was designed to combine and streamline several existing programs to create one unified system that focuses on quality, cost, improvement activities, and the adoption of electronic health record (EHR) technology. As part of this program, eligible clinicians are required to use a certified EHR to report various measures. But why is a certified EHR so important for MIPS? And what happens if clinicians don’t use it? 
- The Importance of Using a Certified EHR for MIPS
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- Standardization: Certified EHR systems ensure a level of standardization. This makes it easier for the Centers for Medicare & Medicaid Services (CMS) to gather, compare, and analyze data across multiple healthcare providers and settings. A consistent approach is crucial for improving care quality and reducing costs.
- Data Integrity: Certified systems undergo rigorous testing to ensure they can accurately capture, calculate, and report MIPS measures. This ensures that the data used to evaluate and reimburse providers is accurate and reliable.
- Improved Patient Care: One of the primary objectives of MIPS is to promote improved patient care. Certified EHR systems facilitate this by enabling features like drug-drug and drug-allergy interaction checks, clinical decision support, and electronic prescribing.
- Promote Interoperability: Interoperability refers to the ability of different healthcare information systems to work together within and across organizational boundaries. A certified EHR promotes interoperability, making sure patient information can be shared and accessed across different care settings, which is a crucial component of MIPS.
- Implications of Not Using a Certified EHR
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- Financial Penalties: MIPS is a performance-based incentive program. Providers can either receive bonuses or penalties based on their performance. Not using a certified EHR can result in significant financial penalties up to 9% of Medicare Part B Payments. This is especially important as the potential percentage penalty or bonus can change year-to-year.
- Reputation Damage: MIPS scores are publicly reported on the Physician Compare website. Using non-certified EHR systems, which may not report data correctly, could lead to a lower score and potentially damage a clinician’s reputation.
- Operational Challenges: Without a certified EHR, providers may face challenges in collecting and reporting data efficiently, leading to increased administrative burden.
- Missed Improvement Opportunities: MIPS is not just about penalties and bonuses; it’s about improving patient care. By not utilizing a certified EHR, providers might miss out on critical insights and opportunities to enhance care quality and patient outcomes.
- Ineligibility for Bonuses: Eligible clinicians and groups have an opportunity to earn bonuses up to 9%. Without a certified EHR, they might not be able to participate in these bonus pools, even if they perform well on other MIPS categories.
In conclusion, the use of a certified EHR is not merely a bureaucratic requirement but a foundational element in driving the healthcare system towards better patient outcomes, reduced costs, and improved care quality. For eligible clinicians, understanding the importance of a certified EHR and the consequences of not using one is crucial to ensure success in the evolving landscape of healthcare reimbursement and quality improvement.
October 10, 2023
By: Karen Perry, OD FAAO
Director Professional Relations, Government Regulation and HIPAA Compliance Privacy Officer