MIPS: Direct Messaging

How does my practice get direct messaging?

Your EHR vendor should be able to supply you with an option for direct messaging and may be able to provide you with a Radius Report to identify those providers in your area who also have direct messaging addresses. You can also get a direct messaging address from State Health Information Exchange entities, regional and local Health Information Exchange entities, as well as private service providers.
If you cannot locate the providers or facilities you contact to get their direct messaging address, call them and ask for it (just as you would for a fax number). 

Why is direct messaging important? 

Under the Merit-based Incentive Payment System (MIPS) reporting requirements in the Promoting Interoperability (PI) category, practices will need to attest to the Prevention of Information Blocking statements. All eligible clinicians within your group must meet this requirement for the entire group to meet the requirement. Direct messaging is one of the Centers for Medicare & Medicaid Services (CMS) certified options to meet these requirements and is often the preferred method of EHR vendors. 

What are the reporting requirements under direct messaging? 

There are two measures that use direct messaging. Both measures include a numerator/denominator submission.

Support Electronic Referral Loops by Sending Health Information

• The numerator is the number of transitions of care and referrals (reported in the denominator) where a summary of care record was created using Certified EHR Technology (CEHRT) and exchanged electronically.
• The denominator is the number of transitions of care and referrals during the performance period for which the MIPS eligible clinician was the transferring or referring clinician.

Support Electronic Referral Loops by Receiving and Incorporating Health Information
The numerator is the number of electronic summary of care records in the denominator for which clinical information reconciliation is completed using CEHRT for the following three clinical information sets:

• Medication – Review of the patient's medication, including the name, dosage, frequency and route of each medication;
• Medication allergy – Review of the patient's known medication allergies; and
• Current Problem List – Review of the patient’s current and active diagnoses.

The denominator is the number of electronic summary of care records received using CEHRT for patient encounters during the performance period for which a MIPS eligible clinician was the receiving party of a transition of care or referral, and for patient encounters during the performance period in which the MIPS eligible clinician has never before encountered the patient.

What are the statements under attestation for information blocking?

A MIPS eligible clinician must attest that they did not knowingly and willfully take action (such as to disable functionality) to limit or restrict the compatibility or interoperability of CEHRT.

A MIPS eligible clinician must attest that they implemented technologies, standards, policies, practices and agreements reasonably calculated to ensure, the greatest extent practicable and permitted by law, that the CEHRT was at all relevant times:

• Connected in accordance with applicable law;
• Compliant with all standards applicable to the exchange of information, including the standards, implementation specifications and certification criteria adopted at 45 CFR Part 170;
• Implemented in a manner that allowed for timely access by patients to their electronic health information (including the ability to view, download and transmit this information); and
• Implemented in a manner that allowed for the timely, secure and trusted bidirectional exchange of structured electronic health information with other health care providers (as defined by 42 U.S.C. 300jj(3)), including unaffiliated providers, and with disparate CEHRT and health information technology (HIT) vendors.

A MIPS eligible clinician must attest that they responded in good faith and in a timely manner to requests to retrieve or exchange electronic health information, including from patients, health care providers (as defined by 42 U.S.C. 300jj(3)) and other persons, regardless of requestor’s affiliation or technology vendor.

Direct messaging is a complicated process, especially as you try to connect with other providers in your area who may not be aware of the responsibilities on their end. If you have additional questions, please contact the Quality Reporting Engagement Group at internal_sales_associate@intrinsiq.com.