Whether reporting under traditional MIPS or using the APM pathway, you are required to report data for the Promoting Interoperability Category. One new measure to review concerns the SAFER Guides.
From the QPP.CMS.gov website:
For Performance Year 2022, you’re required to use an Electronic Health Record (EHR) that meets the 2015 Edition certification criteria, 2015 Edition Cures Update certification criteria, or a combination of both for participation in this performance category.
You must submit collected data for certain measures from each of the 4 objectives measures (unless an exclusion is claimed) for the same 90 continuous days (or more) during 2022.
In addition to submitting measures, you must provide your EHR’s CMS Identification code from the Certified Health IT Product List (CHPL) and submit a “yes” to:
- The Actions to Limit or Restrict Compatibility or Interoperability of CEHRT (previously named the Prevention of Information Blocking) Attestation,
- The ONC Direct Review Attestation,
- The security risk analysis measure, and;
- The SAFER Guides measure (a "no" will also satisfy this measure)
Because these measures appear very similar, some are uncertain whether the Security Risk Analysis and the SAFER Guide measure are the same thing. THEY ARE NOT!
The Security Risk Analysis requirement is unchanged from prior years. You must complete an analysis, correct any deficiencies and implement security updates as necessary from what is learned during that analysis.
New for 2022 is the 'High Priority Practices Guide of the Safety Assurance Factors for EHR Resilience (SAFER) Guides' measure. To meet this measure, MIPS eligible clinicians must attest YES or NO to conducting an annual self-assessment of the High Priority Practices Guide of the SAFER Guides during the 2022 performance period. You can access the SAFER Guides from the Office of the National Coordinator: https://www.healthit.gov/topic/safety/safer-guides
Click on the 'High Priority Practices' option under 'Foundational Guides'. From there, you can download the fillable pdf form. These guides help healthcare organizations assess and address EHR safety and safe use, and highlight best practices.
