Promoting Interoperability (PI) Requirements

This performance category promotes patient engagement and electronic exchange of information using certified electronic health record technology (CEHRT).

2019 Promoting Interoperability Requirements

2019 Promoting Interoperability Requirements was formerly Advancing Care Information (ACI) and counts as 25% of the final score.

This percentage can change due to Special Statuses, Exception Applications, or Alternative Payment Model (APM) participation.

What Promoting Interoperability Data Should I Submit?

Updated for and beginning in 2019, you will submit a single set of Promoting Interoperability Objectives and Measures to align with 2015 Edition CEHRT.  This single measure set includes new and existing Promoting Interoperability performance category measures organized under 4 objectives. Measures are no longer classified as base score or performance score measures.

Requirements

For Performance Year 2019, 2015 Edition CEHRT is required for participation in this performance category.  Participants must submit collected data for certain measures from each of the 4 objectives measures (unless an exclusion is claimed) for 90 continuous days or more during 2019.  In addition to submitting measures, clinicians must submit a “yes” to the Prevention of Information Blocking Attestation, submit a “yes” to the ONC Direct Review Attestation; and submit a “yes” for the security risk analysis measure

Hardship Exceptions

A clinician or group participating in MIPS may submit a Promoting Interoperability Hardship Exception Application, citing one of the following reasons for review and approval: Extreme and uncontrollable circumstances, MIPS eligible clinician in a small practice,  Insufficient Internet connectivity, MIPS eligible clinician using decertified EHR technology, or Lack of control over the availability of CEHRT.

For clinicians participating in MIPS, getting a hardship exception means that the Promoting Interoperability performance category receives 0 weight in calculating your final score and the 25% is reallocated to the quality performance category.  There are some clinicians who will be automatically reweighted based on Special Status (for example, hospital-based clinicians) or their clinician type (for example, a physical therapist, occupational therapist, or clinical psychologist). These clinicians will not need to submit a Promoting Interoperability Hardship Exception Application.  If you are submitting as part of a group, the whole group must qualify for some sort of hardship exception for the group to be reweighted.

How Are Measures Scored?

Beginning in 2019, they simplifying how they score the Promoting Interoperability performance category.  Each measure will be scored by multiplying the performance rate (calculated from the numerator and denominator you submit) by the available points for the measure.  The Public Health and Clinical Data Exchange measures will be awarded full points if a yes is submitted for 2 registries or one yes and one exclusion. Please note that failure to submit a numerator of at least one for measures or claim an exclusion will result in a zero being earned for the Promoting Interoperability performance category.  If exclusions are claimed, the points for those measures will be reallocated to other measures.

Bonus Points

Clinicians, groups, and virtual groups can earn 5 bonus points each for the submission of these optional measures:  Query of Prescription Drug Monitoring (PDMP); and Verify Opioid Treatment Agreement.

How Should I Submit Data?

This information has been updated for 2019.  Individual clinicians, groups, and virtual groups can log in and attest to their promoting interoperability measure data on qpp.cms.gov.  Individual clinicians, groups, virtual groups, and third-party intermediaries can log in and upload their promoting interoperability measure data in an approved file format on qpp.cms.gov.  Authorized third-party intermediaries can perform a direct submission, transmitting data through a computer-to-computer interaction, such as an API.

Third-Party Intermediaries

A third-party intermediary is an entity that collects and submits data on behalf of MIPS eligible clinicians. Intermediaries can be a qualified registry, a qualified clinical data registry (QCDR), a health IT vendor that obtains data from a MIPS eligible clinician’s CEHRT, or a CMS-approved survey vendor.  Certain CMS-approved third-party intermediaries also provide feedback to clinicians throughout the year to support and drive improvement, qualified clinical data registries and qualified registries.

There’s the quick summary of 2019’s Promoting Interoperability (PI) Requirements, formerly Advancing Care Information (ACI).  This information comes from cms.gov. Give us a call and let us help you submit qualifying data to your best benefit.

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