Last Friday, the IRIS Registry sent out an e-mail to IRIS Registry participants requesting practices to indicate whether or not they are on an EHR that is 2015 CEHRT certified. We would like to provide a follow-up and clarification to that email regarding requirements for submitting Quality Measures for the 2019 reporting year.
As you may already know, we are currently in the process of rolling out EyeMD EMR 2.0, which is a 2015 CEHRT. Although the IRIS Registry e-mail suggests that EyeMD EMR 2.0 may be required in order to submit electronic clinical quality measures (eCQMs, which is one of three types of quality reporting mechanisms), EyeMD EMR 2.0 is not required in order to submit other types of Quality Measures including MIPS CQM (referred to in IRIS Registry’s email as QPP) and QCDR measures.
If you have not yet upgraded to EyeMD EMR 2.0 and took a PI hardship exception, EyeMD EMR 1.x customers are still eligible to submit MIPS CQM and QCDR Measures via the IRIS Registry to avoid a penalty for the 2019 reporting year.
We are actively working with the IRIS Registry to map additional MIPS CQM and QCDR measures to maximize your quality measure options for all versions of EyeMD EMR. That being said, both EyeMD EMR Healthcare Systems, Inc. and the American Academy of Ophthalmology believe that it will be significantly more difficult for practices to achieve a MIPS Exceptional Performance Bonus for the 2019 reporting year due to measures being topped out and benchmarking being adjusted to account for the high number of practices that achieved high performance on MIPS CQM measures in previous reporting years.
Although achieving an Exceptional Performance Bonus will be difficult for practices, avoiding penalties is viable for all versions of EyeMD EMR! If your practice has not upgraded to EyeMD EMR 2.0, all that is required in order to avoid a penalty is for you to apply for a PI hardship exception and score at least 30 points between Improvement Activities, Quality, and Cost categories. If you have not already applied for a PI Hardship Exception, now is the time!
If you would like to report quality via eCQM and are currently on EyeMD EMR 1.x, there are conflicting interpretations on whether clinical data is required to be entered into a 2015 CEHRT when reporting clinical quality measures via eCQM. The word “collect” used in the verbiage found in the MIPS QPP User Guide can be interpreted to mean systems that collect data (such as the IRIS Registry), or an EHR that collects data from users. We have sent a letter to CMS asking them to clarify the verbiage in question. If you would like to report quality via eCQM for 2019, please contact Customer Service to discuss options that may be available to you. Please note that reporting via eCQM is not required in order to avoid a penalty.
If your practice requires any further assistance, please reach out to us! We are here to help you navigate through the complex maze of MIPS!
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