Promoting Interoperability: Will the 2019 Proposed Changes Help? Part IV

In earlier parts of this blog series, we discussed the proposed changes for Quality and the Cost categories in MIPS year 3. In this post, we will investigate the major restructuring proposed for the Promoting Interoperability performance category for 2019. With the renaming and redesigning 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 and as a result, positively influence both the quality and the cost of care delivered. 

 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 will no longer be available.

PI Submission Options 

There would be 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

Proposed PI Measures

For 2019 performance year, CMS has proposed addition of new measures, removal of some of the existing measures, and modifications to the specifications of some of the existing measures in the Promoting Interoperability category. Overall, the scoring structure has been simplified to single measure set instead of separate base and performance measures. Some noteworthy proposed changes are:

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

  • One major change you will notice is that 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.

  • 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 by 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 (is worth 10 points in 2018)

SUMMARY OF 2019 PROPOSED 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
Bonus: Verify Opioid Treatment Agreement
5 pts
Num/Den
Health Information Exchange Support Electronic Referral Loops by Sending Health Information
20 pts
Num/Den
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
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

Heavily emphasizing “Providing patients electronic access to their health information” enables CMS to address two issues at once – empower patients, and ensure continuity of care till the optimum level of interoperability between healthcare providers is achieved. The EHR Meaningful Use incentives alone was not successful in creating interoperability in a fee-for-service world. However, this measure might take us a few steps closer to the interoperability goal. It also ties in neatly with the Improvement Activity – Engagement of patients through implementation of improvements in patient portal.

PI Scoring

In the proposed PI measure set, all the measures for which exclusion is not applicable are required. Not reporting on any one of them or answering NO to the Security Risk Analysis will fetch a score of zero for the PI category. This policy is same as 2018. No change there. However, being able to get the measures for which you claim exclusion, reweighted to other measures is new. Obviously, this will not be applicable to the clinicians for whom PI is automatically reweighted to the Quality category, and the clinicians who file the hardship exception.

REWEIGHTING WHEN EXCLUSIONS ARE APPLICABLE

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 conditions in which the PI performance category will be automatically reweighted to the Quality category remain the same as that of 2018. There is one addition though. Automatic reweighting will be applicable to all the new eligible clinician types added – physical therapists, occupational therapists, clinical social workers, and clinical psychologists.

Is Your EHR Ready for 2019 and Beyond?

If you are a MIPS eligible clinician and you haven’t already upgraded to 2015 edition of your EHR, now is the best time to do so. If you switch to 2015 edition now, you’ll have enough time to establish new workflows if needed and test them. You can easily get in 90 days of reporting on the 2015 edition, earn the 10 bonus points for using 2015 CEHRT for current performance year, and hit the ground running in 2019.

If you are an EHR vendor, you can benefit from MyMipsScore’s 2015 certified FHIR® ready EHR plugins without requiring custom integration. Set up your clients for success in MIPS by offering all eCQMs without the hassle of annually updating the eCQMs or undergoing recertification process. Get in touch with us to find how this solution can work for you.

What’s next?

CMS is seeking comment on the weight of the measures, the reweighting, and the scoring policies not only for 2019, but the future years as well. Please let your thoughts known to CMS by September 10th. In case the new measures and scoring methodology is not finalized, the Promoting Interoperability Objective and Measures established for 2018 performance year would be used. As the 2015 CEHRT would still be mandatory for 2019, the entire measure set corresponding to the 2014 CEHRT would be removed. Additionally, the two new opioid measures might be included if they are finalized. Only time will tell if the Promoting Interoperability performance category will live up to its name. The prospects look promising though.

The next part of this series will segue into the MIPS 2019 proposed changes for the Improvement Activities performance category.

 

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