Effective Immediately, CMS renames MIPS ACI to PI

April 27th, 2018 by

CMS continues to refine and streamline incentive programs, this time focusing on Meaningful Use of Electronic Health Record (EHR) for hospitals and the Advancing Care Information (ACI) category for the Merit-based Incentive Payment System (MIPS). As stated by CMS, effective immediately EHR incentive programs and the MIPS ACI category are being renamed to Promoting Interoperability, PI. This change will move these programs into another important phase, increasing focus on interoperability and improving patient access to health information.


CMS published the IPPS Proposed Rule earlier this week announcing the renaming and proposed redesign of the hospital Meaningful Use (MU) program as the “Promoting Interoperability (PI)” program. The proposed changes would apply to the Medicare hospital MU program, and are reflective of some of the scoring methodologies currently applied to the MIPS ACI category.


For example,

  • Threshold scoring, (i.e. pass/fail) will move to performance-based scoring on a continuous scale, where increased measure performance proportionally increases the PI score.
  • If a hospital scores less than 50 out of 100 points on PI, then no PI incentive would be earned, which is also reminiscent of how MIPS PI requires the achievement of the 50-point base score.
  • Finally, like the current MIPS scoring for ACI, an annual security risk audit must also be completed, otherwise PI is 0. Take a look at our MIPS FAQs to see more specifically how MIPS PI (formerly ACI) is scored.


Data interoperability across EHRs is a top priority for CMS, as reflected in the PI proposal. The Administration has reiterated the requirement for 2015 CEHRT in the next calendar year (2019) because key interoperability features require upgrading from 2014 CEHRT. However, CMS also is proposing that the hospital PI program allow a 90-day minimum reporting period, enabling more time for upgrades to 2015 CEHRT.


The hospital PI program would reduce the number of required measures from 16 down to 6 measures. Two measures related to interoperability would be worth 20 points each and a single measure related to providing patient electronic access to their health information will be worth 40 points. In other words, interoperability and patient access to health information would comprise 80 out of the maximum of 100 PI points. Two additional measures related to opioid prescribing are also introduced as optional in 2019, but required in 2020. If they are reported for 2019, each earns 5 bonus points. CMS is sending a clear message about the importance placed upon interoperability, patient access to data and resolving the opioid prescribing crisis.


Although this proposed rule only modifies hospital MU programs, CMS requests feedback on whether similar changes should be made to Medicaid MU for eligible professionals (EPs). This signals that analogous changes may be proposed for MIPS PI in the upcoming 2019 QPP proposed rule.  Stay tuned.

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