In general, MIPS can be scary and overwhelming! Promoting Interoperability (PI) is a performance category that can definitely be intimidating to the point that you just want to avoid it altogether. No worries though, our goal is that after this podcast you will feel a bit more confident and prepared to submit data in 2020 for the PI category for MIPS.
Interoperability, or the use of technology to exchange and make use of information, is in place to make communicating patient information less burdensome and improves outcomes. The MIPS Promoting Interoperability performance category emphasizes the electronic exchange of health information using certified electronic health record technology (CEHRT) to improve:
- Patient access to their health information;
- The exchange of information between providers and pharmacies; and
- The systematic collection, analysis, and interpretation of healthcare data.
Now…let’s get into this.
HOW to successfully submit data for PI
The Centers for Medicare and Medicaid Services (CMS) made relatively few changes to the Promoting Interoperability (PI) category of MIPS this year. The reporting period for PI remains a minimum of 90 consecutive days in 2020. PI is 25% of the final MIPS score. Your EHR must be 2015 edition CEHRT.
Any 90-day period can be selected, however, practices may wish to start collecting PI data well before the last possible performance period start date of Oct. 3, 2020. By starting earlier in the year and not waiting until that last quarter, allows practices to identify areas of deficiency prior to the actual reporting period which is Jan. 1, 2021- March 31, 2021.
Promoting Interoperability remains 25 percent of your final MIPS score for 2020.
In addition to submitting measures, you must provide your EHR’s CMS Identification code from the Certified Health IT Product List (CHPL) and submit a “yes” to:
- The Prevention of Information Blocking Attestation,
- The ONC Direct Review Attestation, and;
- The security risk analysis measure.
You may submit a Promoting Interoperability Hardship Exception Application, citing one of the following reasons for review and approval:
- MIPS eligible clinician in a small practice
- MIPS eligible clinician using decertified EHR technology
- Insufficient Internet connectivity
- Extreme and uncontrollable circumstances
- Lack of control over the availability of CEHRT
If your hardship exception is approved, the Promoting Interoperability performance category will receive zero weight when calculating your final score and the 25% will be redistributed to another performance category (or categories) unless you submit data for this performance category.
Some clinicians 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. To successfully meet the requirements of Promoting Interoperability, you must submit collected data from each of the 4 Objectives Measures. The graph below illustrates the requirements of each measure.
The Security Risk Analysis
The Security Risk Analysis is to protect electronically protected health information (ePHI) created or maintained by the certified electronic health record technology (CEHRT) through the implementation of appropriate technical, administrative, and physical safeguards. At a minimum, MIPS eligible clinicians should be able to show a plan for correcting or mitigating deficiencies and that steps are being taken to implement that plan.
One final tip to help make submitting data to the Promoting Interoperability category of MIPS successful in2020 – DOCUMENT! Be sure to have any supporting documentation, including screenshots of website information stored away in a safe place in case of an audit. These screenshots should be taken during the performance period. CMS requires that practices retain documentation to support all measure submissions for the PI category.
Now you may have a few more questions regarding PI. No worries! Technical assistance is available at no cost to you.