The CMS has implemented a few changes to its 2018 MIPS submission categories. Not only will it be adding a cost category, but it has recently announced the renaming of the Advancing Care Information (ACI) category to Promoting Interoperability (PI) to focus on interoperability, improving flexibility and relieving administrative burdens. The CMS confirmed this will affect only the category name for now, but that is subject to change. The CMS will inform participants and registries if and when anything else changes. This performance category continues to promote patient engagement and electronic exchange of information using certified electronic health record technology (CEHRT).
Your Final Score & Measure Sets
Although the requirements may change with the shifting rules of a performance year, the PI category will make up 25% of your final score. Factors that can affect this percentage are special status, hardship exception or participation in an Alternative Payment Model. The CMS has offered two measure sets (i.e., promoting interoperability objectives and measures, and promoting interoperability transition objectives and measures) for submitting PI data, which can be determined by your CEHRT edition.
If your CEHRT is certified to the 2014 edition, you must use the PI transition objectives and measures set. Otherwise, you may use either set or any combination of the two sets. RISE registry staff is available to assist you with this decision.
Important: The CMS warns that when choosing the combination of technologies path, you may not submit a measure from the PI objectives and measures set that correlates to a measure from the PI transition objectives and measures set. For example, if you submit the Immunization Registry Reporting measure from the PI transition objectives and measures set, you may not submit the correlating Immunization Registry Reporting measure from the PI objectives and measures set.
Clarifications
The CMS has provided the below clarification for those interested in learning more about the PI category:
Participants must submit collected data for four or five base score measures (depending on the CEHRT edition) for 90 days or more during 2018.
In addition to submitting the base score measures, participants must formally certify two declarative statements are true: Prevention of Information Blocking Attestation and ONC Direct Review Attestation.
To improve results, participants may:
- Collect and submit data for up to nine performance score measures (or seven performance score measures if you choose the PI transition objectives and measures set); and
- Earn bonus percentage points by
- Submitting “yes” for one or more additional public health agencies or clinical data registries beyond the one identified for the performance score measure;
- Submitting one or more CEHRT-eligible improvement activity and submitting “yes” to the completion of at least one of the specified improvement activities; and
- Submitting only from the PI objectives and measures set (and only using 2015 edition CEHRT).
Hardship Exceptions
A clinician or group participating in MIPS may submit a Quality Payment Program (QPP) hardship exception application, citing one of the following specified 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; or
- Lack of control over the availability of CEHRT.
For clinicians participating in MIPS, getting a hardship exception means the PI performance category receives zero weight when calculating your final score, and the 25% is reallocated to the quality performance category.
