Update Your Knowledge of MIPS Promoting Interoperability for 2019

EHR use for MIPS 2019

In 2019, there are some changes to the Promoting Interoperability performance category of MIPS. Here’s what you need to know about CEHRT and scoring news for this performance year.

Background: MACRA requires the Quality Payment Program (QPP) to include a MIPS performance category on meaningful use of certified EHR technology, the QPP 2019 rule states. You may recall that Medicare changed the category name from Advancing Care Information (ACI) to Promoting Interoperability (PI) last year.

What Is Interoperability?

Medicare defines interoperability as “health information technology, that enables the secure exchange of electronic health information with, and use of electronic health information from, other health information technology without special effort on the part of the user; allows for complete access, exchange, and use of all electronically accessible health information for authorized use under applicable law; and does not constitute information blocking as defined by the 21st Century Cures Act.” That wording is from the QPP 2019 rule.

What Is New for CEHRT Requirements?

Beginning with the 2019 MIPS performance period, Medicare requires MIPS eligible clinicians to use 2015 Edition certified EHR technology (CEHRT) for the PI performance category. Last performance year (2018), Medicare allowed 2014 CEHRT or a combination of 2014/2015 for MIPS PI.

What Is the Performance Period in 2019?

The performance period for the PI category is a minimum of a continuous 90-day period with the 2019 calendar year. The QPP rule stated that some commenters pointed out “a 90-day performance period will help relieve pressure on clinicians to quickly implement changes and updates from their CEHRT vendors and developers.” To be clear, the 90 days is a minimum, and you can report for a longer performance period if you choose.

What Is the New Scoring Methodology?

The PI category has a new scoring methodology for 2019 instead of the previous base, performance, and bonus scoring:

  • MIPS eligible clinicians must report certain measures from each of four objectives and there will be performance-based scoring at the individual-measure level.
  • Medicare adds together scores for the measures. There are up to 100 possible points per clinician. But we’re not done yet. After adding the measure scores, Medicare divides by 100 to get a percent.
  • To get a score above zero, a MIPS eligible clinician must complete actions in the Security Risk Analysis measure and must submit complete numerator/denominator or yes/no data for all required measures.
    • The Security Risk Analysis measure is required, but it does not contribute to your score. In other words, Medicare thinks you should be doing the actions in the measure anyway.
  • In the e-Prescribing objective, the e-Prescribing measure is worth up to 10 points. The Query of Prescription Drug Monitoring Program (PDMP) and the Verify Opioid Treatment Agreement measure are optional and worth five bonus points each in 2019.
  • The Health Information Exchange objective has the lengthily named Support Electronic Referral Loops by Sending Health Information measure. It is worth up to 20 points. The similarly named Support Electronic Referral Loops by Receiving and Incorporating Health Information is also worth up to 20 points.
  • Under the Provider to Patient Exchange objective, the Provide Patients Electronic Access to Their Health Information measure is worth up to 40 points.
  • The Public Health and Clinical Data Exchange objective requires a yes/no response for two different public health agencies or clinical data registries for any of the objective measures to earn 10 points. Submitting a no without an exclusion results in a zero score.

Tip: To see the 2019 scoring methodology in table form, check out Table 41 on page 1148 of the QPP rule. Table 42 has the 2020 plan.

What About You?

Do you think there was enough time to adjust to these changes for MIPS performance year 2019?




Deborah works on a wide range of TCI SuperCoder projects, researching and writing about coding, as well as assisting with data updates and tool development for our online coding solutions. Since joining TCI in 2004, she’s covered the ins and outs of coding for radiology, cardiology, oncology and hematology, orthopedics, audiology, and more.

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