This content was excerpted from EyeNet’s MIPS 2019; also see the Academy’s MIPS hub page.
Promoting interoperability (PI) is the MIPS electronic health record (EHR)–based performance category. Until April 2018, it was known as advancing care information (ACI), which had evolved out of the EHR meaningful use (MU) program. Since 2018, the PI performance category has undergone some sweeping changes. To score points for this performance category, your EHR must be a 2015-edition certified EHR technology (CEHRT).
Three Basic Features Remain the Same
Select a reporting mechanism. Like last year, you can report your PI measures manually via the IRIS Registry, the CMS QPP attestation portal, or possibly your EHR vendor (check that your vendor offers this option, and ask about fees).
Perform measures for 90 days. As in 2018, PI has a minimum performance period of at least 90 consecutive days.
Earn up to 25 points for your MIPS final score. CMS gives PI a default weight of 25% when it calculates your MIPS final score (0-100 points), meaning PI can contribute up to 25 points to that score.
CMS Has Given PI a Major Overhaul
PI has a new scoring methodology, and there have been wholesale changes to the PI measures. Several measures were eliminated, and others were renamed, modified, and/or combined.
PI is now arranged around four objectives: 1) e-Prescribing; 2) Health Information Exchange; 3) Provider to Patient Exchange; and 4) Public Health and Clinical Data Exchange. Each objective has at least one measure associated with it (see Table 10: Promoting Interoperability at a Glance).
Fall short with even just one measure and your PI score will be 0%. In order to earn any score for the PI performance category, you must either 1) report or, if an exclusion is available, 2) claim an exclusion for all the required measures. If you fail to do that, your PI score will be 0%.
You may be able to claim exclusions. Exclusions are available for most of the PI measures (see Table 11: Promoting Interoperability Exclusions at a Glance). For example, there are two exclusions available for the Support Electronic Referral Loops by Receiving and Incorporating Health Information measure. If you qualify for and claim either of those exclusions, the 20 points available for that measure would be reallocated to another measure.
Not all PI measures have exclusions. There is no exclusion for the Provide Patients Electronic Access to Their Health Information measure, which CMS has described as “the crux” of the PI performance category.
The e-Prescribing objective’s two new opioid-related measures are optional in 2019; therefore, they don’t need exclusions.
Three Critical Attestations
You must submit “yes” for these three attestations. Failure to do so will result in a PI score of 0%.
Submit “yes” to attest that you performed the Security Risk Analysis measure. In 2019, as in 2018, this measure is mandatory—but you no longer earn points for it. The analysis must be done at some point during the 2019 performance year, and it must involve an analysis of the CEHRT that you have in place during your 90-day performance period, but it doesn’t have to take place during that 90-day performance period. This security risk analysis should be familiar to practices as it has long been a requirement of the HIPAA Security Rule.
Submit “yes” for the Prevention of Information Blocking attestation. Attest “yes” to three statements about how you have implemented and used your EHR system. This requirement reflects a CMS concern that practices might “knowingly and willfully” take action to limit and restrict the compatibility or interoperability of CEHRT.
Submit “yes” for the ONC Direct Review attestation. The ONC—otherwise known as the Office of National Coordinator for Health Information Technology—is responsible for certifying EHR systems as CEHRTS, and for monitoring CEHRTS to make sure they continue to meet their certification requirements. Occasionally, ONC may need to conduct a “direct review” of a vendor’s EHR product (for example, if ONC has a reasonable belief that faults within the EHR system may present a risk to public health). By submitting “yes” to this attestation, you agree to cooperate with ONC in such a review.
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