Promoting Interoperability: What's New in MIPS 2018?

As the submissions for 2017 performance year wrap up, it’s perfect time to get started with 2018. In our previous blogs, we discussed the Quality and Cost categories. In this post, we focus our attention on the Promoting Interoperability (formerly ACI) category and the noteworthy changes for performance year 2018.  

 3 noteworthy changes in the  Advancing Care Information (ACI)  category for  MIPS 2018 .

 

Additional Bonus Option

There are two PI measure sets available for the eligible clinicians and groups to choose from. Both measure sets offer the same earning potential for the “Base” and “Performance” measures as points are adjusted accordingly. However, there is a slight advantage to using 2015 edition EHR exclusively and earn 10 more bonus points.

Promoting Interoperability Objectives and Measures

2015 edition EHR, or a combination of 2014 and 2015 EHR editions is required to choose this option.

Base Measures – 5 measures (max 50 points)

Performance Measures – 9 measures (max 90 points)

Bonus Potential – 25 points

(An additional 10 bonus points for using 2015 edition certified EHR exclusively)

2018 Promoting Interoperability Transition Objectives and Measures

This is the only option if for reporting using a 2014 edition EHR.                                                    

Base Measures – 4 measures (max 50 points)

Performance Measures - 7 measures (max 90 points)

Bonus Potential - 15 points

 

 

If you are considering upgrading to 2015 certified version of your EHR, now would be a good time to do so as only 90 consecutive days of PI data is required. The use of 2014 EMR has been extended to 2018, but it might not be an option in the reporting year 2019.

 

Additional Registry Reporting Options 

Providers can report to a registry to earn 10 performance points in 2018 just like last year. But unlike 2017 when reporting to Immunization Registry was the only registry reporting option to earn performance points, in 2018 providers have multiple registries to pick from. Depending on the measure set, providers can choose to report to any one of the following registries to earn 10 performance points:

2018 Promoting InteroperabilityTransition Objectives and Measures

  • Immunization Registry Reporting

  • Syndromic Surveillance Reporting

  • Specialized Registry Reporting

Promoting Interoperability Objectives and Measures

  • Immunization Registry Reporting

  • Syndromic Surveillance Reporting

  • Electronic Case Reporting

  • Public Health Registry Reporting

  • Clinical Data Registry Reporting

Providers can report to an additional registry (not reported under the performance score) and earn 5  bonus points. In other words, a provider cannot earn points under both the performance score and bonus score for reporting to the same registry.

 

Exclusions and Exceptions Clarified

MACRA 2018 Final Rule explains more clearly the exclusions and exceptions available to MIPS eligible clinicians. Both provide distinct flexibilities to providers under specific conditions and thus it’s important to understand the difference between the two.

1.      EXCLUSIONS 

Exclusions are available to all the eligible clinicians who report data for the Promoting Interoperability category if they meet certain criteria defined for certain base measures. For instance, exclusion can be claimed for the E-Prescribing measure, by a MIPS eligible clinician who writes fewer than 100 permissible prescriptions during the performance period. Claiming the exclusion allows the eligible clinicians to complete the PI Base Requirements and earn an PI score. 

Claiming an exclusion does NOT reweight the Promoting Interoperability (PI) category to 0%. 

Exclusions are available for E-Prescribing, Health Information Exchange (Send a Summary of Care, Request/Accept Summary of Care). However, exclusion CANNOT be claimed for Security Risk Analysis and Provide Patient Access measures. They have to be completed in order to complete base requirements and earn an PI score.

2.      EXCEPTIONS 

CMS will reweight the PI category to 0% and reassign its weight (25%) to the Quality performance category (making it 75%) in certain situations as per the provisions in the 21st Century Cures Act and MACRA. Reweighting can either be automatic or requested by filing an application.

a. Automatic Reweighting: The PI category will automatically be reweighted to 0% without submitting any application for:

  • Hospital-based MIPS eligible clinicians

  • Non-Patient-Facing clinicians or groups with >75% NPF clinicians

  • Ambulatory Surgical Center (ASC) based MIPS eligible clinicians

  • MIPS eligible Physician Assistants, Nurse Practitioners, Clinical Nurse Specialist, and Certified Registered Nurse Anesthetists

b. Reweighting by Hardship Exception Application: Eligible clinicians facing insurmountable challenges in the way of using an EHR can submit an application by Dec 31, 2018 to claim the hardship exception and get the PI category reweighted to 0%.

  • Clinicians in a Small Practice (1-15 eligible clinicians) facing overwhelming barriers to adopting a certified EHR (new hardship exception introduced in 2018)

  • Clinicians whose EHR got decertified during the 2018 performance year

  • Clinicians who have insufficient internet connectivity

  • Clinicians facing extreme and uncontrollable circumstances caused by natural disasters

  • Clinicians who don’t have control over availability of Certified EHR technology

[Read a complete overview of Promoting Interoperability Category for 2018]

The 2018 version of MyMipsScore guides you through each measure set for the Promoting Interoperability performance category and all the related options to help you analyze and maximize your performance in each performance category.

Learn how you can get MyMipsScore for your organization.



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