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No EHR? No problem. Eagle Consulting has extensive experience working with practices that still do paper charting to maximize their MIPS incentives.

Many MIPS participants are under the impression that an electronic health record (EHR) is necessary to participate in MIPS as a result of the Meaningful Use program’s evolution though the last several years. This is not true. There is no requirement for participants to use an EHR. In fact, individual clinicians and/or practices can earn a MIPS incentive, no EHR required!

For practices with 15 or fewer clinicians, a 100% MIPS performance score is even possible – all without an EHR.

The only category that requires an EHR is the Promoting Interoperability (PI) category.

This category, with its roots in the old Meaningful Use program, requires (among other things, such as a security risk assessment) the use of an EHR. CMS has given ‘small practices’ (defined as 15 or fewer clinicians) the choice to opt out of the Promoting Interoperability category. To forego PI, a practice must annually “apply” for an exception (i.e. submit an electronic waiver), and an exclusion will be automatically granted. Thus, PI is no longer a requirement, and its points would be reallocated to the Quality category.

Maximizing MIPS without an EHR

Eagle assists non-EHR users by weeding through 250+ quality measures to find the 7-9 that are best suited to their workflows and specialties. The practice staff will learn to collect the data efficiently without the assistance of an electronic health record. A similar process is used for selecting the improvement activities. The aim is to select measures and activities that best conform with your established workflows while also bringing in added value to your patients in order to align with the MIPS program goals. Because there is no real-time monitoring feature when participating in MIPS with out an EHR, Eagle will provide ongoing troubleshooting, check ins, and active coaching throughout the performance period to ensure you hit your goals.

Feel the push of the electronic record weighing down on you?

Don’t panic. CMS has vowed to keep this exclusion in place for small practices throughout the program. If you do use an EHR, Eagle advises you to learn the PI category, regardless of participation. Learn the measures and get familiar with how this category would fit with your workflow. While CMS has stated their intent to keep the exclusion on board for the duration of the MIPS program, they could just as easily withdraw this promise. Eagle can help you get prepared for the worst-case scenario, submit your application for the exclusion, and max out all other MIPS categories to earn the maximum incentive from CMS.

Interested in participating without an EHR in 2019 or 2020? Contact us today!

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