E-Prescribing | MIPS PI Measures for 2024 Reporting

Definition of Terms

Prescription:
The authorization by a MIPS eligible clinician to a pharmacist to dispense a drug that the pharmacist would not dispense to the patient without such authorization.

Permissible Prescriptions:
All drugs meeting the current definition of a prescription as the authorization by a clinician to dispense a drug that would not be dispensed without such authorization and may include electronic prescriptions of controlled substances where creation of an electronic prescription for the medication is feasible using CEHRT and where allowable by state and local law.

Reporting Requirements

NUMERATOR:
Number of prescriptions in the denominator generated and transmitted electronically using CEHRT.

DENOMINATOR:
Number of prescriptions written for drugs requiring a prescription in order to be dispensed other than controlled substances during the performance period; or number of prescriptions written for drugs requiring a prescription in order to be dispensed during the performance period.

Scoring Information

• Required for Promoting Interoperability Performance Category Score: Yes
• Measure Score: 10 points
• Eligible for Bonus Score: No

Note: In order to earn a score greater than zero for the Promoting Interoperability performance category, MIPS eligible clinicians must:

• Complete Security Risk Analysis measure
• Complete the High Priority Practices SAFER Guide measure
• Complete the ONC Direct Review attestation (optional)
• Attest to the Actions to limit or restrict compatibility or interoperability of CEHRT statement
• Submit their complete numerator and denominator or Yes/No data for all required measures
• Submit their CMS certification identification number
• Submit their level of active engagement for the Public Health and Clinical Data Exchange measures
• Failure to report at least a “1” in all required measures with a numerator or reporting a “No” for a Yes/No response measure will result in a total score of 0 points for the Promoting Interoperability performance category.
• Submit data for a minimum of 180 consecutive days within the calendar year

Additional Information

• MIPS eligible clinicians must use technology certified to ONC Certification Criteria for Health IT necessary to meet the CEHRT definition (88 FR 79307).
• To check whether a health IT product has been certified to ONC Certification Criteria for Health IT, visit the Certified Health IT Product List (CHPL) at https://chpl.healthit.gov/.
• Certified functionality must be used as needed for a measure action to count in the numerator during a performance period. However, in some situations the product may be deployed during the performance period but pending certification. In such cases, the product must be certified by the last day of the performance period.
• If an exclusion is claimed for the e-Prescribing measure, the 10 points for the e-Prescribing measure will be redistributed equally among the measures associated with the Health Information Exchange objective: 5 points to the Support Electronic Referral Loops by Sending Health Information measure and 5 points to the Support Electronic Referral Loops by Receiving and Incorporating Health Information measure.
• Actions included in the numerator must occur within the performance period.
• Authorizations for items, such as durable medical equipment, or other items and services that may require a MIPS eligible clinician’s authorization before the patient could receive them, are not included in the definition of prescriptions. These are excluded from the numerator and the denominator of the measure.
• Instances where patients specifically request a paper prescription may not be excluded from the denominator of this measure. The denominator includes all prescriptions written by the MIPS eligible clinicians during the performance period.
• As electronic prescribing of controlled substances is possible, MIPS eligible clinicians may choose to include these prescriptions in their permissible prescriptions where feasible and allowable by state and local law. If a MIPS eligible clinician chooses to include such prescriptions, he or she must do so uniformly across all patients and across all allowable schedules for the duration of the performance period.
• Over the counter (OTC) medications are excluded from the definition of prescription.
• A MIPS eligible clinician needs to use CEHRT as the sole means of creating the prescription, and when transmitting to an external pharmacy that is independent of the clinician’s organization, such transmission must use standards adopted for EHR technology certification.
• MIPS eligible clinicians may claim the exclusions if they are reporting as a group. However, the group must meet the requirements of the exclusion as a group.
• When MIPS eligible clinicians choose to report as a group, data should be aggregated for all MIPS eligible clinicians under one Taxpayer Identification Number (TIN). This includes those MIPS eligible clinicians who may qualify for reweighting through an approved Promoting Interoperability hardship exception, hospital or ASC-based status, or in a specialty which is not required to report data to the Promoting Interoperability performance category. If these MIPS eligible clinicians choose to report as a part of a group practice, they will be scored on the Promoting Interoperability performance category like all other MIPS eligible clinicians.

Regulatory References

• For further discussion, please see the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) final rule: 81 FR 77227.
• For additional discussion, please see the 2018 Physician Fee Schedule final rule – Quality Payment Program final rule: 83 FR 59795.
• In order to meet this objective and measure, MIPS eligible clinicians must use technology certified to the criterion at 45 CFR 170.315(b)(3).

Certification Standards and Criteria

Below are the corresponding certification criteria for electronic health record technology that support this measure.

Certification Criteria:
Below are the corresponding certification criteria for health IT that support this measure.
§170.315(b)(3) Electronic Prescribing