Cash In on Promoting Interoperability
The Advancing Care Information (ACI) performance category – one of four performance categories in the Merit-based Incentive Payment System (MIPS) – is now the Promoting Interoperability (PI) performance category.
What’s In a Name?
For whatever reason, the Centers for Medicare & Medicaid Services (CMS) renamed the performance category. Nothing else has changed about the category.
Under MIPS, the PI performance category is worth 25 points out of a maximum 100-point final score in MIPS. The other three performance categories and their default point values for 2018 are:
- Quality = 50 points
- Cost = 10 points
- Improvement Activities = 15 points
What’s the Point?
The goal of the PI performance category — similar to its predecessor, the Medicare Electronic Health Record (EHR) Incentive Program — is to promote patient engagement and the electronic exchange of health information using certified EHR technology (CEHRT).
For the 2018 performance period, as in the 2017 performance period, there are two measure set reporting options:
- PI Objectives and Measures
- 2018 PI Transition Objectives and Measures
As in the 2017 performance period, you can report the 2018 PI Transition Objectives and Measures if you have:
- 2015 Edition CEHRT;
- 2014 Edition CEHRT; or
- A combination of both 2014 and 2015 Editions.
As in the 2017 performance period, you can report the PI Objectives and Measures if you have:
- 2015 Edition CEHRT; or
- A combination of both 2014 and 2015 Editions that support these measures.
Download the PI measure specifications from the qpp.cms.gov website, here.
The PI performance category score of 25 points is the sum of three parts:
- Required Base Score = 50 percent
- Performance Score = up to 90 percent
- Bonus Score = up to 25 percent
This makes it possible (but not probable) to earn a maximum score of up to 165 percent, but the score is capped at 100 percent, for a maximum 25 points.
To meet the minimum reporting requirements in the PI performance category, you must:
- Use CEHRT Edition 2014 and/or 2015
- Collect data for a minimum of 90 consecutive days in 2018 and submit the data by the deadline.
- Submit a “yes” to the Prevention of Information Blocking Attestation
- Submit a “yes” to the ONC Direct Review Attestation
- Submit a “yes” for the Security Risk Analysis measure, and at least a 1 in the numerator for the remaining base score measures, or submit an exclusion for the base score measures
Note: The security risk analysis can be performed at any time during 2018; it does not have to be performed during the 90-day collection period.
Tip: The 2018 Quality Payment Program final rule added exclusions for the ePrescribing and Health Information Exchange measures for those who conduct such activities for fewer than 100 patients during the performance period.
MIPS eligible clinicians and clinician groups can earn bonuses in the corresponding 2020 payment year, in addition to a +/- 5 percent payment adjustment, by:
- Reporting “yes” for one or more additional public health agencies or clinical data registries beyond the one identified for the performance score measure (5 percent bonus)
- Reporting “yes” to the completion of at least one of the specified Improvement Activities using CEHRT (10 percent bonus)
- Reporting only from the PI Objectives and Measures set using only 2015 Edition CEHRT (10 percent bonus)
You May Be Exempt
Just because you do not have CEHRT Edition 2014 or 2015, doesn’t let you off the hook. You may be exempt from the PI performance category only if you meet one of the following criteria:
- You’re one of the following types of MIPS eligible clinicians:
- Ambulatory Surgical Center-based
- Hospital-based (including off-campus outpatient)
- Physician assistants
- Nurse practitioners
- Clinical nurse specialists
- Certified registered nurse anesthetists
- Non-facing patient clinicians
- You’re a MIPS eligible clinician and:
- You work in a small practice
- You use decertified EHR technology
- You have insufficient internet connectivity
- You have extreme and uncontrollable circumstances (such as a hurricane)
- You have no control over whether CEHRT is available
Note: You must submit an application by December 31, 2018, to request exemption (with the exception of those affected by the extreme and uncontrollable weather events in 2017, who are automatically exempt).
If you are exempt from the PI performance category, CMS will reweight your Quality performance category score to 75 points (50+25).
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