In the MIPS Proposed Rule, CMS says they are considering a requirement that all MIPS vendors be capable of submitting three of four MIPS Categories. Your current PQRS vendor does not do this yet, and the addition is a big deal.
In today's market a large number of vendors providing PQRS capabilities, under QCDR, Qualified Registry, EHR Direct Submission, or EHR Submission Vendor. Most physicians use one of these vendors to avoid the PQRS penalty for non-filing, either directly or through an ACO.
For Meaningful Use, most physicians currently submit attestations manually on the CMS Website. There are a small handful of vendors offering electronic submission software, and a small number of provider groups have created "automated batch attestation" interfaces. So far, the vast majority of EP's have their MU attestation submitted manually one at a time on the CMS web site.
If CMS finalizes this proposal, all existing PQRS vendors would be required to add the ability to submit their Meaningful Use (Advancing Care Information) measures electronically as well. (And existing Meaningful Use vendors would be required to add PQRS submission capabilities.)
Although the regulations are still in proposed form, it appears that the CPIA (Clinical Practice Improvement Activity) data will take the form of attested values, rather than content extracted from CEHRT.
Bottom line is a good news / bad news scenario. Good news is that CMS may require vendors to build and deploy capabilities you don't yet have, to save some time. Bad news is that you are likely to have to change vendors to take advantage of this capability - and there is not yet a model for evaluating one vendor against another. Stay tuned! Citations on Page 28183 of the MIPS Proposed Rule
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