Promoting Interoperability: A MIPS 2019 Makeover

The Promoting Interoperability (PI) performance category has undergone a complete makeover for 2019 MIPS performance year. Although the PI category weight and the minimum reporting period have stayed the same, everything else has changed significantly. With a redesign of this category, CMS aims at achieving better transition of care, improved communication between the caregivers, getting data for public health initiatives, and empowering patients to take charge of their care. Thus, positively influencing both the quality and the cost of care delivered. 

In this blog, we will take a close look at all the changes in the PI category: the new objectives, measures, exclusions, exceptions, reweighting, and how they impact the PI category score.

Will the proposed changes for MIPS 2019 PI performance category help promote interoperability?

PI Weight and Performance Period

The Promoting Interoperability category weight stays the same at 25% and so does the performance period that needs to be reported, a minimum of 90 continuous days. Eligible clinicians can report data for the entire calendar year if they want to. If clinicians choose to submit data as a group for Quality category, they will need to report as a group for all the performance categories.

2015 CEHRT Required

Beginning 2019, the use of 2015 certified edition EHR will be mandatory. 2014 certified edition will no longer be allowed. As 2015 CEHRT will be required, the bonus points for using one are no longer available. Note: At the time of submission, providers will also need to specify the Certification IDs for the 2015 CEHRT or the certified modules they used.

PI Submission Options 

New terminology has been introduced by CMS for MIPS 2019 to match the submitter experience. There are three submission options available to submit PI category data for MIPS:

  1. Direct submission to CMS via an API integrated in the EHR

  2. Log in to the EIDM account and upload the data

  3. Log in to the EIDM account and attest (Security Risk Analysis and reporting to Registries)

Performance Category
Collection Type
Individual
Collection Type
Group
Submission Type
Promoting Interoperability (PI)
-
-
Direct
Log in and Upload
Log in and Attest

Promoting Interoperability (PI) Measures

For 2019 performance year, some new measures have been introduced, and some existing measures removed or modified for the PI category. Overall, the scoring structure has been simplified to single measure set instead of separate base and performance measures. Some noteworthy changes are:

  • The concept of checks and balances has been introduced with the two opioid related measures: Prescription Drug Monitoring Program (PDMP) and the Verification of Opioid Treatment.

  • All the measures will be scored except the Security Risk Analysis. The logic behind that is all physicians (irrespective of their MIPS eligibility) need to comply with HIPAA’s administrative and physical safeguards, and thus be meeting the requirements anyway.

  • All measures are required (unless exclusion is claimed)

  • Points vary for the measures based on the importance. This is also a big change from previous performance years in which all measures were worth 10 points.

  • There is no bonus for reporting to more than two required public health agencies or clinical data registries.

  • No bonus for reporting Improvement Activities via the EHR either as clinicians are expected to be using a 2015 certified EHR in MIPS year 3.

  • The “Provide Patient Access” measure has been modified to “Provide Patients Electronic Access to Their Health Information” and the weight has been increased to 40 points (from 10 points in 2018)

SUMMARY OF MIPS 2019 PI MEASURES

Objectives
Measures
Max Points
Reporting
Exclusion
e-Prescribing e-Prescribing
10 pts
Num/Den
Available
Bonus: Query of Prescription Drug Monitoring Program (PDMP)
5 pts
Num/Den
N/A
Bonus: Verify Opioid Treatment Agreement
5 pts
Num/Den
N/A
Health Information Exchange Support Electronic Referral Loops by Sending Health Information
20 pts
Num/Den
Available
Support Electronic Referral Loops by Receiving and Incorporating Health Information
20 pts
Num/Den
Available
Provider to Patient Exchange Provide Patients Electronic Access to Their Health Information
40 pts
Num/Den
N/A
Public Health and Clinical Data Exchange Choose two of the following:
Immunization Registry Reporting
Electronic Case Reporting
Public Health Registry Reporting
Clinical Data Registry Reporting
Syndromic Surveillance Reporting
10 pts
Yes/No
Available
Protect Patient Health Information Security Risk Analysis
0 pts
Yes/No
N/A

By heavily emphasizing “Providing patients electronic access to their health information” CMS aims to empower patients, and further interoperability which Meaningful Use incentives failed to deliver. It also ties in neatly with the Improvement Activity Engagement of patients through implementation of improvements in patient portal.

PI Scoring

For 2019, all the PI measures are required except the bonus measures. Not reporting any one of them or answering NO to the Yes/No measures will fetch a score of ZERO for the PI category. However, measures for which you claim exclusion will be reweighted to other measures.

REWEIGHTING WHEN EXCLUSIONS ARE APPLICABLE

 
MIPS-2019-Reweighting of PI-Measures.png
 
  • e-Prescribing exclusion: When clinician qualifies for exclusion from reporting this measure, the 10 points will be redistributed to both measures under the Health Information Exchange objective equally making their weight 25 points each.

  • Support Electronic Referral Loops by Receiving and Incorporating Health Information exclusion: The weight will be shifted to the other measure in the Health Information Exchange objective making it worth 40 points.

  • Public Health and Clinical Data Exchange exclusion: Exclusion can be claimed for just one or both the public health /clinical data registries required to be reported to. If exclusion is claimed for just one, then the one being reported will carry all 10 points. If exclusion is claimed for both, the 10 points are allocated to the Provide Patients Electronic Access to Their Health Information measure, making it worth 50 points.


AUTOMATIC REWEIGHTING OF PI

The PI performance category will be automatically reweighted to the Quality category to certain eligible clinicians types 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 PA, NP, CNS, CRNA, PT, OT, Qualified speech-language pathologists, Qualified audiologists, Clinical psychologists, and Registered dietitian or nutrition professionals

REWEIGHTING WITH HARDSHIP EXCEPTION

Eligible clinicians can submit an application by Dec 31, 2019 to claim the hardship exception and get the PI category reweighted to 0%. Following MIPS eligible clinicians can file for exception:

Not having CEHRT is not sufficient by itself to qualify for reweighting.
— MIPS 2019 PI Fact Sheet
  • MIPS-eligible clinicians in small practices

  • MIPS-eligible clinicians using de-certified EHR technology

  • Lack of control over the availability of CEHRT

  • Insufficient Internet connectivity

  • Extreme and uncontrollable circumstances (Natural Disasters, Practice Closure, Severe Financial Distress, or Vendor Issues)


THE SMALL PRACTICE PI EXCEPTION MYTH

Although small-practices can claim a hardship exception, they don’t get the hardship exception just by the virtue of being a small practice. The practice will need to justify the hardship circumstances and then CMS will decide. On a similar note, not having a 2015 Certified EHR is not a sufficient to claim hardship exception. Clinicians will need to provide reasoning when filing the application. Simply choosing to continue using a 2014 Certified EHR will not suffice.

The Impact of PI Restructuring on MIPS Score

It will be much harder to score 100% in the PI category in 2019 as compared to previous MIPS performance years as all measures (except the Yes/No measures) will be scored on performance and are required. Additionally, if you fail to report on any measure without claiming exclusion, your entire PI category score will become ZERO. The maximum point opportunity also went down to 110 (from 165 in 2018). As PI category accounts for 25% of MIPS score, any reduction in PI score will impact the MIPS score and the payment adjustments.

The requirement to use 2015 Certified EHR adds to the complexity. Although the 2015 edition Certification can be obtained on the last day of the performance period (Dec 31, 2019), it will considerably limit the ability to pick the best 90 days (required performance period) for providers. Additionally, the EHR would need to support the 2015 Edition functionality throughout the 90 day performance period. As noted above, at the time of submission, providers will also need to specify the Certification IDs for the 2015 CEHRT or the certified modules they used.

Need More Help With PI Category?

If you are not sure if you could claim an exclusion or exception or need help with understanding the MIPS 2019 PI category requirements for your practice, our MIPS experts can help you. MyMipsScore also offers 2015 Certified EHR module that enables EHRs to fulfill the PI category requirements without undergoing re-certification or requiring custom integration. Get in touch with us to find how this solution can work for you.


 

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