**Effective April 23, 2018, CMS has renamed the Advancing Care Information category of MIPS. It is now known as Promoting Interoperability (PI).
The name change was announced by CMS on April 23. ASCRS has been working with the medical community to advocate for simplified and streamlined scoring in the MIPS program. In addition to simplified scoring, CMS has signaled that it plans to include reforms to the MIPS Program in the 2019 Medicare Physician Fee Schedule and Quality Payment Program proposed rule that will move this category to a new phase of EHR measurement with an increased focus on interoperability and improving patient access to health information. The proposed rule is expected in the summer of 2018.
2019 Category Overhaul
Following advocacy by ASCRS and the entire medical community to simplify and streamline the requirements and scoring of the category, CMS finalized significant policy changes for the Promoting Interoperability 2019 performance period. CMS has done away with the confusing base and performance scores in the category and will focus on a single set of measures. In addition, CMS has eliminated the ASCRS-opposed measures that required patient action. While ASCRS supports the simplified requirements for this category, we continue to oppose its all-or-nothing scoring, which requires participants to report on all required measures or earn no points in the category. We will continue to advocate for modifications to this scoring methodology.
2019 New and Modified Measures
In addition to removing the patient action measures, CMS has also modified the previous Receive a Summary of Care and the Clinical Information Reconciliation measures and combined them into a new measure, Support Electronic Referral Loops by Receiving and Incorporating Health Information. For 2019, only encounters for which the physician or group receives a summary of care from another provider are included in the denominator of this measure. The numerator is the number of patients for whom a summary of care was received and clinical information reconciliation was performed. Some EHR systems may not be ready to report this modified measure for 2019, and therefore, CMS is offering an exclusion for practices that are not able to report it. The Send a Summary of Care measure was renamed Support Electronic Referral Loops by Sending Health Information to conform with the modified measure, but the requirements were not changed for 2019. CMS also renamed the Patient Electronic Access objective to Provider to Patient Exchange and renamed the Patient Access Measure to Provide Patients Electronic Access to their Health Information. The description and requirements of the measure did not change.
Finally, in conjunction with overall administration efforts to combat opioid abuse, CMS is adding two optional measures related to opioid prescribing to this category. Neither measure will be required for 2019 in order to give EHR systems time to implement the measures. For systems that can report the measures, physicians can earn up to 5 bonus points per measure in 2019. In our comments on the proposed rule, ASCRS noted that ophthalmologists are not likely to prescribe opioids and asked for an exclusion. CMS did not offer the exclusion for 2019 since the measures are optional but noted that it will consider implementing exclusions in future years.
Small Practice Hardship Exemption
For 2019, CMS is continuing to offer a small practice hardship exemption for the PI category. Practices of 15 or fewer eligible clinicians must submit a hardship application by December 31, 2019, to have the 25% weight of the PI category re-weighted to the Quality category.
Promoting Interoperability (PI) Category Weight
For 2019, the PI category score will continue to be weighted at 25% of the overall MIPS final score. If CMS determines that at least 75% of MIPS-eligible clinicians are “meaningful users” of EHR in future years, the scoring weight for PI could be lowered to no less than 15% of the overall score.
In some cases, CMS may determine a provider is excluded from one or more of the other MIPS categories and will re-weight the individual provider’s quality performance score to make up the difference. If a physician or small practice receives the small practice hardship exemption, the 25% weight of the category will be redistributed to Quality.
Promoting Interoperability Category Performance Period
For 2019, physicians must report PI for at least any 90-day period to be considered full participants. Physicians have the option to report more than 90 days, up to a full year.
Use of 2015 CEHRT
For 2019, all participants must use 2015 certified electronic health technology (CEHRT).
Promoting Interoperability Category Score
A physician’s or group’s PI category score will be based on the cumulative performance on each of the required measures. The streamlined measure set includes four objectives, with five required measures, and two bonus measures. Physicians must report on all required measures or receive zero points for the entire category.
Each measure will be scored based on the submission of a numerator and a denominator, except for the measures associated with the Public Health and Clinical Data Exchange objective, which require “yes” or “no” submissions. All measures must have at least 1 in the numerator or answer “yes” to receive credit for the measure.
The measures will be scored by dividing the numerator by the denominator and multiplying by the designated weight of the measure. The measures are assigned points similarly to the previous methodology, where performance between 1% and 10% equals 1 point, 11% and 20% equals 2 points, etc. Each measure score is then multiplied by the individual measure’s weight, which varies from measure to measure. For example, if a practice reports that 85 out of 100 possible patients were given electronic access to their health information, then the performance on the measure is 85%. Since this measure’s weight is worth up to 40 points, the clinician’s score would be a total of 34 points toward the total category score.
For 2019, CMS is adding two new measures to the e-Prescribe objective that seek to curb opioid abuse. Given that some EHR systems will not be ready to report these measures for 2019, they will be optional and worth up to 5 bonus points each. The Query of Prescription Drug Monitoring Program (PDMP) will be required in 2020 and the Verify Opioid Treatment Agreement will be optional in both 2019 and 2020.
There are no longer any bonus points available for using 2015 CHERT or reporting to additional registries.
Security Risk Analysis
The Security Risk Analysis is no longer a measure included in the PI category. However, since physicians and practices are required to review electronic security protocols under HIPAA, they will still have to attest that a security risk analysis was performed sometime during the performance year when reporting 2019 PI data for MIPS. This attestation will not be included in the category score, but if the physicians or groups fail to attest to performing the security risk analysis, they will receive zero points for the category, regardless of whether they reported any other data.
Public Health and Clinical Data Exchange Objective
For 2019, CMS will continue to include a Public Health and Clinical Data Exchange objective, which requires that participants report on at least two of the five types of registry reporting. There are exclusions available for each type of registry, so if physicians or groups do not have a total of two registries available to report to, they may claim an exclusion for one or both required registries. Alternatively, if physicians or groups have two of the same type of registry available to report to, they may attest to reporting to both registries of the same type to fulfill the requirement for the objective. Ophthalmologists who report to the IRIS Registry may attest to the Clinical Data Registry measure; however, they likely will not have another available registry of any type and will be required to take an exclusion for the second registry.
To receive credit for reporting to any of the data registries, a physician or group must answer “yes” when attesting or claim the exclusion. Answering yes or claiming exclusions for two registries will earn the physician or group the full 10 points for the objective.
Promoting Interoperability Objectives and Measures
For a list of 2019 PI objectives and measures, please download the ASCRS PI Category Guide.
For additional information, you may contact Allison Madson, manager of regulatory affairs, at email@example.com or 703-591-2220.