2019 Promoting Interoperability (PI) Requirements:

What Changed in Year 3?

CMS updated the PI performance category for the 2019 performance year to include several new requirements, as well as modifications to certain other requirements. Here are the top reminders and changes to be aware of in the 2019 performance year:

You must use EHR technology certified to the 2015 Certified Electronic Health Record Technology (CEHRT) Edition.

The 2015 CEHRT Edition functionality must be in place by the first day of the PI performance period, and certified by the last day of the performance period. The performance period for PI is a minimum of a continuous 90-day period. The timing of this 90-day period is up to you. For example, if your 90-day PI performance period begins October 1, 2019, then your 2015 Edition CEHRT functionality must be in place by October 1, 2019 and the product certified to the 2015 Edition criteria by the last day of the performance period, December 31, 2019. If you are not sure which edition your EHR is certified to, then we recommend that you search for your EHR product(s) using the Certified Health IT Product List (CHPL) website (please note that this website is not supported by Internet Explorer).

New Measures and Bonus Points!

In 2019, CMS has moved away from classifying PI measures as base, performance or bonus score measures. Additionally, the following four measures are no longer eligible to report: 1) Patient-Specific Education, 2) View, Download, or Transmit (VTD), 3) Secure Messaging, and 4) Patient-Generated Data (PGH). In 2019, there is only one set of PI objectives and measures, based on the 2015 Edition CEHRT. The new measure set includes eleven measures spread across four objectives: 1) e-Prescribing, 2) Health Information Exchange, 3) Provider to Patient Exchange, and 4) Public Health and Clinical Data Exchange. Clinicians must report measures from each of the four objectives, unless they qualify for an exclusion.

Clinicians, groups, and virtual groups can earn five bonus points each for the submission of these two new optional measures:

  • Query of Prescription Drug Monitoring Program (PDMP)
  • Verify Opioid Treatment Agreement

To get full credit in the PI category, SURS practices must do the following:

  • Collect your data in EHR technology with 2015 Edition functionality (certified by the last day of the performance period) for a minimum of any continuous 90-day period in 2019, up to the full calendar year;
  • Submit a “yes” to the Prevention of Information Blocking Attestations;
  • Submit a “yes” to the ONC Direct Review Attestation;
  • Submit a “yes” that you have completed the Security Risk Analysis measure in 2019; and
  • Report the required measures from each of the four objectives or claim their exclusion(s).

You can still submit an application for the PI hardship exception.

  • The PI hardship exception will continue to be available for small practices. This means that if your practice has 15 or fewer eligible clinicians, you can request that the PI category be reweighted to zero and reallocated to the Quality performance category. The PI hardship exception is also available to practices of all sizes who have decertified EHR technology, insufficient internet connectivity, lack of control over the availability of CEHRT, and practices that face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress or vendor issues. The Promoting Interoperability Hardship Exception Application for Performance Year 2019 will open early summer 2019 and close December 31, 2019. For more information on Hardship Exceptions, click here.

You can find more details outlining each element of the PI measures in the Promoting Interoperability Measure Specifications and information on the ways to submit data to CMS on the 2019 Promoting Interoperability Measures Requirements website. In addition, CMS has published a fact sheet on the Promoting Interoperability Performance Category.