In case you haven’t read through the 2019 Final Rule, you need to know that the Promoting Interoperability (PI) category has changed quite a bit from the first two years of the MIPS program. Though the category weight remains at 25% (25 of 100 MIPS points), healthcare providers will find it significantly more difficult to achieve the full 25 points. In 2017 and 2018, clinicians had ample opportunities to earn bonus points, and the scoring methodology of base measures plus performance measures made the category almost a slam dunk. Not so in 2019, and here’s why.
- Performance measures have been reduced from seven measures to five, which are organized in four objective areas: ePrescribing, health information exchange (HIE), provider to patient exchange, and public health and clinical data exchange. Each of these measures are worth 10 to 40 points – a low score on the 40-point “Electronic Access” measure will have significant impact on the overall category score.
- Total possible points have been reduced from 165 to 110, with 100 points based on the five performance measures above. A maximum PI score is achieved by earning at least 100 points, so there is now little room for error. Ten bonus points can be earned through two ePrescribing measures that address the opioid epidemic; these brand new bonus measures will be worth five points each, but details on how to maximize and capture them are early in development.
- The scoring methodology has changed; instead of calculating the PI score through a combination of base plus performance measures, CMS will be scoring the five PI performance measures independently. All five measures must be reported or excluded, or a score of zero will result for the entire category. The Security Risk Analysis is still required but does not earn points for the category.
- Healthcare providers are now required to report PI through 2015 CEHRT (Certified EHR Technology), and all measures are either newly developed or have evolved from Stage 3 measures. These changes are intended to support greater interoperability and patient access, and align MIPS with the Medicare PI Program requirements for hospitals.
Though the evolution of the PI category is an intentional progression by CMS toward greater electronic health record interoperability and increased patient access to electronic health information, it does represent a significant area of risk. Many clinicians who earned 25 MIPS points in previous performance years could see a 12% – 16% score erosion in 2019 simply because of the new methodology and new measures in the PI category.
We’d be happy to help you identify your potential problem areas as we move into the 2019 MIPS performance year. Schedule a MIPS consultation with our experts today!