CMS has finalized what can only be described as an “overhaul” of the Promoting Interoperability (PI) performance category of MIPS for 2019.
This category (previously known as Advancing Care Information, and formally associated with the EHR Incentive Program, or Meaningful Use) has been an ever-shifting series of challenges for healthcare providers and practice managers over the years. Other EHR focused programs like the Inpatient Quality Reporting Program (IQR) have also re-oriented to be aligned with and named Promoting Interoperability.
For MIPS in 2019, the category weight remains at 25% and we still have a 90-day reporting period, but substantial changes have been applied to the objectives, measures, exclusions, and scoring methodology. The complexity of the PI workflows and the dependence on your EHR vendor for validated data can make adapting to the changes challenging. In addition, recent scoring changes will require many practices to improve their PI category performance in 2019 just to achieve similar scores to 2017 and 2018.
“Recent scoring changes will require many practices to improve their PI category performance in 2019 just to achieve similar scores to 2017 and 2018.”
Let’s review some of the greatest threats to your 2019 MIPS score the changes to Promoting Interoperability represent. If you or your practice manager has uncertainties around any of the changes, post in the comments or reach out now because Mingle Health is here to help.
New Interoperability Focus
There is an increased focus on the PI category as an attempt to improve EHR interoperability across the country. Although the title of many “meaningful use-related” programs (MIPS PI being one of them) has aligned under the name Promoting Interoperability, practice managers still need to understand the differences between the MIPS program, the Medicaid reporting program, and what they may need to report for the clinicians versus the hospital reporting.
Key Takeaway: Putting all of the different programs under the same name of “Promoting Interoperability” is likely to cause some amount of confusion. In the past, this kind of confusion has led to missed reporting, penalties, and lost revenue. Be sure you understand how the individual programs impact your practice’s reimbursements and revenue.
New 2015 CEHRT Edition Requirements
In order to attest for PI in the 2019 reporting year, you must have the 2015 certified edition of your EHR installed for the entire duration of your selected 90-day period. This edition change is more than just a simple upgrade. It fundamentally changes the requirements for your EHR vendor to participate in the market and will come with new functionality and new workflows. There will certainly be additional training of workflows which need to be implemented for patients to fall into the numerators of the new and changed measures.
Key Takeaway: You must have your 2015 certified EHR in place for your entire 90-day reporting period. As a result of the new edition, many workflows may change and affected staff will need training in order to ensure success. Plan for your upgrade date accordingly.
The total number of PI category points has been reduced from 165 points in 2018 to 110 points in 2019. Both years had a “point cap” of 100, but the 50-point base score has been removed (see table 1). This removal, along with other changes will make it more challenging for practices to achieve high category scores this year. All of the required measures must be reported or excluded, or the practice will earn a score of zero for the entire category.
Key Takeaway: The new scoring methodology presents a challenge for practices and even those who have earned perfect scores in the past may see point loss or category failure if they depend on prior performance rates and methods. Proactively examine your PI score under the new rules to determine your level of risk.
All measures are either new measures or have evolved out of the Stage 3 EHR Incentive Program measures (see table 1). Although some measure titles may be the same or similar as the Stage 2 or Transition measures from prior MIPS years, in many cases the details have been modified. The modifications and additions have a focus on greater interoperability and patient access, both areas where practices have tended to struggle or rely on exclusions in prior years.
Key Takeaway: Many measures have been modified or added. Be sure you understand the details of each measure and how the changes may impact your practice.
Table 1: Promoting Interoperability Measures for 2019
|Objective||Individual Requirement||Maximum Points||Status|
|Query of PDMP||5||New Measure/Bonus|
|Verify Opioid Treatment||5||New Measure/Bonus|
|Health Information Exchange||Sending Health Information||20||Stage 3 Modified/Required|
|Receiving/Incorporating Health Information||20||New Measure/Required|
|Provider to Patient Exchange||Patient Electronic Access||40||Stage 3 Required|
|Public Health and Clinical Data Exchange||Choose Two:
Electronic Case Reporting
Public Health Registry
Clinical Data Registry
|10||Stage 3 Modified/Required|
|n/a||Security Risk Assessment||0||HIPAA/Required|
|n/a||Information Blocking Attestations||0||New Language/Required
Busy EHR Vendors
Because your EHR has a new set of requirements, your practice may find some functions you enjoyed no longer exist as a part of their vendor’s re-design or have become a less actively supported function. The development focus will likely be on new functionality required by the 2015 certification criteria.
Key Takeaway: EHR vendors that struggle with development resources often have slower support time in upgrade years as more of their staff is focused on rolling out new functionality instead. Discuss issues with your vendor early and expect reasonable deadlines to be communicated.
Beware of Exclusions
Prior years of both MIPS and the EHR Incentive Program (MU) saw many practices relying on exclusions to complete the requirements. In past years, taking an exclusion meant you no longer needed to worry about that measure. In 2019, exclusions pose a large risk because when a measure is excluded those points are not “excused” in any way, but are instead shifted to another measure, often a more difficult one. The most dangerous exclusion this year is, “Support Electronic Referral Loops by Sending Health Information.” Not only was this a widely used exclusion, but CMS has ruled that the points on that measure, if excluded, will not be announced until the 2020 final rule and applied retroactively.
Key Takeaway: If your practice has been taking exclusions, they may be at an increased risk. Examine your workflows and only use exclusions as a last resort against category failure.
Failure is Possible
Instead of calculating the PI score through a combination of base and performance measures, scoring on each of the objectives will be measured independently. Every objective is required (or excluded), and if those selections aren’t made in a required objective, a score of zero will be applied to the entire category. This change, combined with how the exclusions will function, makes it appear CMS is returning to more of a pass/fail methodology.
Key Takeaway: Failing the PI category is possible in 2019. Expect that your staff will need protected time to learn about the program and scoring changes this year. Reach out for additional help to reduce reporting burden this year.
Don’t go it alone
The 2019 version of the MIPS Promoting Interoperability program goes beyond the prior requirements of meaningful use and into a new phase of EHR measurement. Although the category has been streamlined down to focus on key strategic areas for Health IT, your practice may find the scoring and implementation of these new workflows to be a big challenge.
Because we know PI will be a source of point loss for our clients this year, Mingle Health now offers advanced PI consulting services. Our Health IT experts guide you through a step-by-step process of learning how to monitor the measures and identify problems early. We assist you through the recommended workflow changes and help you engage your clinicians along the way.
Is your practice prepared for the changes? Leave a comment below. To learn more about how we can help, get in touch here or ask your account manager.
Mingle expert Alysen Casaccio walks you through changes to Promoting Interoperability and the threats to your MIPS score in 2019.