Did you receive a perfect score in the MIPS Promoting Interoperability category in 2017 or 2018? Most practices did in those first two years, but this year, it will be much more difficult to achieve even a high score let alone a perfect one with the changes for MIPS Promoting Interoperability 2019.

The worst case scenario? You could receive a “zero” in the MIPS Promoting Interoperability 2019 category and be subject to a 7% cut in your Medicare reimbursements for payment year 2021.

CMS has made major changes to the MIPS Promoting Interoperability 2019 category that promise to throw even the most diligent practice off tract and negatively impact your total MIPS score. If you want to increase your positive MIPS adjustment, avoid negative payment adjustments, and earn a portion of the exceptional performance fund, acing the PI category is imperative.

But time is quickly running out — October 3^rd, the last day to begin the 2019 reporting period — is right around the corner. Keep reading for the top ten fast facts you should know to earn a perfect score, and avoid the dreaded “zero.”

1. You Still Have Time

The reporting period for the MIPS Promoting Interoperability 2019 performance category in is only 90 days — NOT a full calendar year. That means there’s still time to implement the changes needed to comply with the MIPS 2019 requirements. The last possible day you can begin your reporting period is October 3, 2019.

2. Didn’t Have to Submit in Previous MIPS Reporting Years? Listen Up.

You may have to in 2019. In addition to the medical specialties that already report, the following specialties are now required to report in 2019:

• Physical therapists
• Occupational therapists
• Qualified speech language pathologists
• Qualified audiologists
• Clinical psychologists
• Registered dieticians or nutrition professionals

3. All MIPS Participants Must Use 2015 CEHRT

However, you’ll no longer earn bonus points related to using CEHRT (certified EHR technology) or reporting to additional registries. If you don’t currently have CEHRT but plan to, the uncertified 2015 edition must be in place by the first day of your reporting period (October 3, for example), and it must be certified by the last day of your reporting period (December 31^st, for example).

4. MIPS Promoting Interoperability Category Is Still 25 percent of Your Total Score

Happily, CMS has eliminated the confusing base and performance scores and replaced them with a single set of five measures. These five measures are grouped under four objectives. However, the scoring is still all-or-nothing. To avoid receiving a “zero” for the entire MIPS Promoting Interoperability 2019 category, you must report on all five of measures (unless you’ve claimed an exclusion). If you are granted an exclusion from a specific measure, the points associated with that measure will be redistributed to another measure(s).

5. CMS Has Eliminated and/or Combined Several Measures

There are no longer any measures that require action on the part of patients. The “Receive a Summary of Care” and the “Clinical Reconciliation” measures have been combined into one new measure: “Support Electronic Referral Loops by Receiving and Incorporating Health Information.” To score this measure, the denominator is the number of encounters where you/your group receives a summary of care from another provider. The numerator is the number of patients where a summary of care was received AND you performed a clinical information reconciliation. Not all EHR systems are currently able to report this measure. You can earn an exemption for this measure if your EHR system is not yet able to report it.

6. CMS Has Changed the Names of Several Measures/Objectives

CMS did not, however change those measures’ corresponding requirements. Renamed measures include:

• The “Send a Summary of Care” measure was renamed “Support Electronic Referral Loops by Sending Health Information.”
• The “Patient Electronic Access” objective was renamed “Provider to Patient Exchange.”
• “Patient Access” measure was renamed to “Provide Patient Electronic Access to their Health Information.”

7. CMS Has Added 2 Measures Relating to Opioid Prescribing

These measures are OPTIONAL in reporting year 2019 to allow EHR systems time to update. However, you can earn up to five bonus points per measure for reporting them. The measures are:

• Query of Prescription Drug Monitoring Program (optional in 2019, required in 2020)
• Verify Opioid Treatment Agreement (optional in 2019, optional in 2020)

8. The Security Risk Analysis Is No Longer a Measure

But you must still attest that you/your group performed a security risk analysis sometime in 2019 at the time that you report the rest of your MIPS Promoting Interoperability data. While the attestation is not part of your score, fail to do it you will receive a “zero” for the entire MIPS Promoting Interoperability 2019 category.

9. CMS Continues to Offer Exemptions for the Entire PI Category

If your practice plans on requesting an exemption, you must do so by December 31^st, 2019. If approved for an exemption, the 25% weight for the MIPS Promoting Interoperability category will be reweighted to the Quality category. Reasons to apply for an exemption include:

• MIPS eligible clinicians in a small practice (15 or less providers under the tax identification number) can apply for the Small Practice Hardship exemption.
• MIPS eligible clinician using decertified EHR technology
• Insufficient internet connectivity
• Extreme and uncontrollable circumstances (i.e. a natural disaster)
• Lack of control over the availability of CEHRT

10. Your Group Must Report All 5 Required Measures to Avoid Receiving a “0” in the Entire Category

Most of the measures are scored based on dividing a numerator by a denominator, and then multiplying that result by the designated weight of the particular measure. All measures must have at least a 1 for the numerator to be scored. There are two measures that are scored with yes/no answers instead of the numerator/denominator. You must answer “yes” to each of these measures to be scored and receive credit.

11. Prepare by Implementing Plan and Training Now

There’s not much time left. It’s urgent you take action immediately. The new MIPS Promoting Interoperability 2019 changes for the patient engagement and CEHRT performance category have significant technical, workflow and training challenges that need to be implemented as soon as possible. This is where physician and MIPS expert, Michael Stearns, MD, CPC, CFPC, CRC, can help you. Dr. Stearns takes you through the 2019 MIPS Promoting Interoperability changes step-by-step. What you learn during this training will help you avoid the very real possibility of scoring zero points in the PI category.

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