The CY 2019 Medicare Physician Fee Schedule Final Rule involves a slew of regulatory changes that will apply to the 2019 performance year. Of course, wading through the final rule to find and understand the most important features of the policy can be grueling; but you’re in luck, because we’ve already done it so you don’t have to! In today’s blog, we’re focusing on the MIPS Promoting Interoperability (PI) category.

Background

The 2019 scoring methodology was introduced to provide more flexibility in scoring and focus more on patient care and health data exchange through interoperability. The goal was to remove measures that focused on patient action and instead focus on objectives that promote interoperability between health care providers and health IT systems to provide more coordinated care while ensuring patients have access to their medical data.

In 2017, CMS began an informal process to allow submission of new PI measures for potential inclusion in year 3 (2019). As a result of this process, they proposed two measures, Query of PDMP and Verify Opioid Treatment Agreement, with the goal of aligning requirements of the PI performance category with the requirements of the Medicare Promoting Interoperability Program for eligible hospitals and CAHs.

Overview of Major Changes

Objectives

The PI Category for MIPS comprises four (4) objectives which include a combination of new and existing measures:

• e-Prescribing- These core goals promote interoperability between health care providers and health IT systems to support safer, more coordinated care.
• Health Information Exchange- These core goals promote interoperability between health care providers and health IT systems to support safer, more coordinated care.
• Provider to Patient Exchange- Promotes patient awareness and involvement in their health care through the use of APIs, and ensures patients have access to their medical data.
• Public Health and Clinical Data Exchange- supports the ongoing systematic collection, analysis, and interpretation of data that may be used in the prevention and controlling of disease through the estimation of health status and behavior.

Measures

Following is a list of all measures in the PI category, broken down by objective, as well as a list of measures that have been removed from previous performance years:

e-Prescribing Objective

• e-prescribing (10 points)
• Query of Prescription Drug Monitoring Program (PDMP) (new measure, 5 bonus points)
• Verify Opioid Treatment Agreement) (new measure, 5 bonus points)

Health Information Exchange Objective

• Support Electronic Referral Loops By Sending Health Information Measure (20 points)
• Support Electronic Referral Loops By Receiving and Incorporating Health Information (20 points)

Provider to Patient Exchange

• Provide Patients Electronic Access to Their Health Information (40 points)
• Public Health and Clinical Data Exchange (choose 2 for a total of 10 points)

Public Health and Clinical Data Exchange (choose 2)

• Immunization Registry Reporting
• Electronic Case Reporting
• Public Health Registry Reporting
• Clinical Data Registry Reporting
• Syndromic Surveillance Reporting
• Security Risk Analysis

Measures removed from previous performance years:

• Request/Accept Summary of Care
• Clinical Information Reconciliation
• Patient-Specific Education
• Secure Messaging
• View, Download or Transmit
• Patient-Generated Health Data

Points Associated with Measures

Each measure will be scored based on the MIPS eligible clinician’s performance for that measure based on the numerator and denominator, except for the measures associated with the Public Health and Clinical Data Exchange objective, which require “yes or no” submissions. The Security Risk Analysis measure will still be a required measure, but without points. It's also important to note that case minimum exclusions exist for ePrescribing & Health Information Exchange measures.

Score Calculation

The scores for each of the individual measures are added together to calculate the PI performance category score of up to 100 possible points. In other words, the numerator and denominator for each measure would translate to a performance rate for that measure and would be applied to the total possible points for that measure.

New for 2019

For 2019, re-weighting extends to the following additional clinician types:

• Physical therapists
• Occupational therapists
• Speech-language pathologists
• Audiologists
• Clinical psychologists and registered dietitians and nutrition professionals

Re-weighting can also occur through one of the following approved applications:

• New hardship exception for clinicians in small practices (15 or fewer clinicians);
• New decertification exception for eligible clinicians whose EHR was decertified, retroactively effective to performance periods in 2017.
• Significant hardship exceptions—CMS will not apply a 5-year limit to these exceptions

Continuing Exemptions

The following exemptions will carry over from previous years:

• Non-physician clinician type: Nurse practitioner, physician assistant, clinical nurse specialist, or certified registered nurse anesthetist, physical therapists, occupational therapists, clinical social workers, and clinical psychologists
• Significant hardship (e.g. lack of internet, extreme and uncontrollable circumstances, small practice)
• 50% or more of patient encounters occurred in practice locations where no control over the availability of CEHRT
• Non-patient facing clinicians
• Hospital-based clinicians
• ASC-based clinicians
• Automatic re-weighting for extreme and uncontrollable circumstances
• MIPS eligible clinicians using decertified EHR Technology, exception available for no more than 5 years 

If you want to learn more, dig even deeper by enrolling in the free Value-Based Care Institute (VBCI) online course on Promoting Interoperability.