MIPS 2019, 2 of 4

Promoting Interoperability (PI) is not the biggest piece of the 2019 MIPS pie, but it still represents 25% of the total MIPS score which, in turn, determines the amount of your Medicare payment adjustment in 2021. PI is the category with the largest requirement changes from last year. There's a great deal to cover, so without further preamble, here goes:

Category: Promoting Interoperability (PI)
Weight: 25% of total MIPS score

Web Resources: 

• Overview with links to detailed information 
• The overview has a link at the bottom to a PDF with more detail, titled 2019 Promoting Interoperability Information Blocking Fact Sheet. (This is misleading, the "Blocking Fact" part of the title appears to be a mistake on the web page - just click on it to get the 2019 Promoting Interoperability Fact Sheet.  Interestingly, this is not the only confusing thing we'll cover in this post!)
  
• To explore measure specifications, click on Explore Measures in the box labeled View Promoting Interoperability Measures, found about halfway down the page.

Reporting Period: 90 or more continuous days during 2019, which means that the last possible day to begin is October 3, 2019.

Scoring: 110 points possible, capped at 100, scored as a % of 25 total MIPS points.  Example: if your score in this category is 80%, you'll get 20 points for the Promoting Interoperability category (80% of 25 points) to add to your MIPS score.  Confused yet?  If so, just ask us for help, or simply try to maximize your PI score.

MANDATORY ATTESTATIONS

Mandatory Attestations are the first part of your reporting. We're giving only a very rough summary here; please look into them further using the Web Resources above.

• Prevention of Information Blocking: All AuroraEHR users should be able to submit a "yes", basically agreeing that there was no disabling of the EHR to prevent information sharing, that a patient portal and Direct messaging were used, and that you responded in good faith to retrieve/exchange EHR data, including patients and other providers.
• ONC Direct Review Attestation: A "yes" essentially means that you agree to cooperating with ONC in evaluating CEHRT or use of CEHRT.
• Security Risk Analysis in 2019:  You must submit a "yes", which means that you must perform a security risk analysis.
• This is unscored, but it is mandatory.  If you can't submit "yes" then you will score zero points for Promoting Interoperability as a whole, regardless of how well you have done in its other measures.
• You can download the Security Risk Assessment Tool which should be of help.

 OBJECTIVES

Important:  It is a requirement that measures must be reported from each of the 4 objectives, even if what you report is an exclusion. Failure to to report for a single objective will result in a zero score for the entire Promoting Interoperability Category, no matter how well you have performed in the other three objectives.

e-Prescribing: 

• Scoring: 10 points, plus up to 10 bonus points. If exclusions are claimed, then the points get allocated to Health Information Exchange. 
• Exclusion: There is an exception for clinicians writing fewer than 100 prescriptions during the performance period.
• Measure 1: e-Prescribe. You're scored on the percentage of all prescriptions that you write which were done electronically.  For AuroraEHR clients, you would use Rcopia.
• Measure 2: PDMP Query. This is optional, but you get 5 bonus points for completing this.  Talk to us about making this available through Rcopia if it's possible to do for your state.  The sooner the better, since there are setup and registration steps involved.
• Measure 3: Verify Opioid Treatment Agreement. Also optional, worth 5 bonus points.

Provider to Patient Exchange:

• Scoring: 40 points, by performance rate
• You must provide patients electronic access to their health information via an available API or a patient portal, in a timely way.
• Patients must be able to view, download, or transmit their information.
• You'll meet this measure by completing encounters in a timely way, which will automatically upload the required information to Bridge. 

Health Information Exchange:

• Measure 1: Support Electronic Referral Loops by Receiving and Incorporating Health Information: 
  
• Scoring: 20 points, based on the percentage of electronic summary of care records received for which clinical information reconciliation was performed.
• An exclusion exists for clinicians/groups with less than100 transitions of care/referrals/new patients. If reporting as a group, this means the entire group received less than 100 transitions of care/referrals/new patients.
• You must receive at least one CCDA and do a clinical information reconciliation.
• You can do this through the menu option AuroraEHR ->  Secure MD Toolbox Messages.
•  Measure 2: Support Electronic Referral Loops by Sending Health Information
• Scoring: 20 points, based on the percentage of summary of care records you sent which were sent via Direct message.
• An exclusion exists for any MIPS-eligible clinician/group who transfers a patient to another setting or refers a patient fewer than 100 times during the performance period.
• Doing this is an important part of your success, but will involve some changes in the way you finish encounters.  Part 3 of this series will delve into this measure in more detail.

Public Health and Clinical Data Exchange: - Report on two measures from this objective. If you claim an exclusion, the points are reallocated to the Provider to Patient Exchange objective.

• Scoring: 10 points
  
• Immunization Registry Reporting
• Syndromic Surveillance Reporting
• Electronic Case Reporting
• Public Health Registry Reporting
• Clinical Data Registry Reporting  

Four 2018 measures were removed:

• Patient-Specific Education
• View, Download, or Transmit (VDT)
• Secure Messaging
• Patient-Generated Health Data

Blog posts in this series:

Part 1 (Overview of 2019 MIPS)
Part 2 (Promoting Interoperability)
Part 3 (Health Information Objective )
Part 4 (Quality Performance Category)