Excerpted from “MIPS—What’s New for 2019”, a two-part EyeNet series (January and February, 2019), published online ahead of print. You also should bookmark EyeNet's MIPS 2019 (also published online ahead of print) and the Academy's MIPS hub page.
The EHR-based performance category has had a major overhaul. CMS has restructured PI, which now has a new scoring methodology. The agency also has made some changes to the PI measures, with some measures being renamed, modified, combined, and removed.
You need to use 2015 CEHRT. In 2018, you could use an EHR system that was certified as a 2014- or 2015-edition certified EHR technology (CEHRT); in 2019, your EHR must be a 2015-edition CEHRT.
Some PI measures have been removed. CMS eliminated the 2018 PI transition measure set altogether, and it also eliminated four measures from the PI measure set: Patient-Generated Health Data; Patient-Specific Education; Secure Messaging; and View, Download, or Transmit.
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 of the four objectives has at least one measure associated with it:
1) e-Prescribing objective has three associated measures:
- e-Prescribing (report a numerator of at least 1 or claim an exclusion)
- Query of Prescription Drug Monitoring Program (PDMP) (optional bonus measure)
- Verify Opioid Treatment Agreement (optional bonus measure)
2) Health Information Exchange objective has two associated measures:
3) Provider to Patient Exchange objective has one associated measure:
4) Public Health and Clinical Data Exchange objective has five associated measures, and you must report two measures; or report one measure for two different registries (or public health agencies); or perform one measure and claim one exclusion; or claim two exclusions.
Fall short with even just one measure and your PI score will be zero. In order to earn any score for the PI performance category, for each of the required measures, you must either 1) report a numerator of at least 1 or 2), if an exclusion is available, claim an exclusion. If you fail to do that, your PI score will be zero.
Exclusions are available for most of the PI measures. For example, there are two exclusions available for the Support Electronic Referral Loops By Receiving and Incorporating Health Information measure. If you qualify for either of those exclusions, the 20 points 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.
The two new opioid-related measures are optional in 2019, and therefore, they don’t need an exclusion.
For most PI measures, you will be scored based on your performance rate. You can, for example, score up to 10 points for the e-prescribing measure; if your performance rate is 80%, you would score eight points. However, the scoring is not performance rate–based for the five measures in the Public Health and Clinical Data Exchange objective.
The Security Risk Analysis measure. In 2019, as in 2018, the Security Risk Analysis measure is mandatory—but you no longer earn points for it. The analysis must be done at some point during 2019, but it doesn’t have to take place during your 90-day PI performance period.
Who has to participate in PI? As in 2018, some clinicians may be excused from PI. The six new types of MIPS eligible clinicians are automatically excepted from PI, unless they choose to participate.
Hardship exceptions. CMS is continuing its significant hardship policy for PI. For example, if you are in a small practice, you may be excused from PI if you successfully apply for a significant hardship exception.
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