Posted on October 6, 2020
The MIPS Promoting Interoperability (PI) category, which replaced the Meaningful Use program, establishes requirements that promote the electronic exchange of information using certified electronic health record technology (CEHRT). 2015 Edition CEHRT is required to attest to the PI category. MIPS eligible clinicians and groups are scored on their performance on several PI measures. Making sense of all of the requirements can be challenging, so in this blog we will explain how to report PI and the potential impact on your final MIPS score.
What's New in 2020?
There were very few changes to the PI category for the 2020 performance year:
- CMS will continue the Query of Prescription Drug Monitoring Program (PDMP) measure as an optional measure (available for bonus points).
- The optional Verify Opioid Treatment Agreement measure was removed.
- The threshold for a group to be considered hospital-based was reduced. Instead of 100% of clinicians, more than 75% of the clinicians in a group must be hospital-based individual MIPS eligible clinicians for the group to be considered hospital-based.
2015 Edition CEHRT Required
The PI category is worth 25% of your total MIPS score and requires a minimum of any continuous 90-day reporting period during the calendar year. MIPS eligible clinicians and groups must have a 2015 Edition EHR to attest to PI (formerly known as Stage 3 under Meaningful Use). A 2015 Edition EHR must be in place by the first day of the PI performance period, and the product must receive its certification by the last day of the PI performance period. This means your PI performance period could be October 3, 2020 through December 31, 2020.
Not sure if your EHR vendor is 2015 certified? You can search for your EHR product(s) on the Certified Health IT Product List (CHPL) website here.
Important: The last day your 2015 Edition EHR must be in place is October 3, 2020. If you are still using 2014 Edition CEHRT, you should contact your EHR vendor to find out if and when they will receive 2015 Edition certification. There are many changes between the 2014 Edition and 2015 Edition CEHRT, so it’s important to discuss the new functionality, workflows and training with your EHR vendor to minimize any disruption to your practice.
PI Objectives and Measures
There is a single set of objectives and measures that will be scored based on a clinician’s or group’s performance. All measures are required from each of the 4 objectives (except for the bonus measure), unless an exclusion is claimed.
More details about what’s required for each of the PI measures can be found here.
Remember, if you are reporting MIPS to a Qualified Registry, it does not count towards the Public Health and Clinical Data Exchange objective. Click here for more information on how to engage with MDinteractive’s Clinical Data Registry to ensure you earn PI points for this measure.
Important: In addition to reporting on the above measures, clinicians must also report their EHR's CEHRT identification code and attest to (answer "yes"):
- Completing a Security Risk Analysis;
- The Prevention of Information Blocking Attestation; and
- The ONC Direct Review Attestation.
Instructions on how to attest to the PI category in your MDinteractive account can be found here.
The PI performance category is 25% of your total MIPS score. The total number of potential PI points is 105 points in 2020, but the score is still capped at 100 maximum points. Each PI measure is scored based on your performance on the measure (e.g., the numerator/denominator submitted or answering “yes,” if applicable), and all of the points will be added together to calculate your total PI performance category score.
While most of the measures have an exclusion available, it's important to remember that when an exclusion is claimed, the points for the measure will be redistributed to another measure or measures. More information on how the points are redistributed for the exclusions can be found on our website here.
Let's take a look at how the scoring for individual measures and the total PI score will be calculated:
Performance Score Illustration:
A numerator/denominator of 170/200 for the Provider to Patient Exchange measure (worth up to 40 points) would have a performance rate of 85%. The points for this measure would be calculated as follows:
.85 (performance rate) x 40 (total possible measure points) = 34 points (added to your total PI score)
PI Score Illustration:
If all of the PI measures combined earned 75 points for a clinician, the total PI score would be 18.75 points:
(75 (PI points) x .25 (PI category weight)) x 100 = 18.75 PI points
Important: Since scoring is based on your performance for each measure, earning the full 25 points for PI in your final MIPS score could be more difficult. And, if you do not report a required measure, or claim an exclusion for a required measure, you will receive a total score of 0 for the PI performance category. It is important to pay close attention to your performance on the measures and make improvements where necessary to maximize your PI score and Medicare payment adjustments.
PI Reweighting and Exemptions
Under certain circumstances, CMS will reweight the PI category to 0% and the 25% would be added to the Quality score.
If you qualify for a certain “Special Status” or are a certain type of clinician, the PI category will be automatically reweighted to 0%. You do not need to submit a Quality Payment Program hardship exception application if you qualify for automatic reweighting.
The following list of clinicians would have PI automatically reweighted and would not have to submit a PI Hardship Exception Application:
Ambulatory Surgical Center (ASC)-based
Clinical nurse specialists
Certified registered nurse anesthetists
Qualified speech-language pathologists
Registered dietitian or nutrition professionals
*Groups are designated as a non-patient facing group or a hospital-based group when more than 75% of the MIPS eligible clinicians in the group meet the definition of non-patient facing or hospital-based as individuals.
Remember, a group qualifies for automatic reweighting when 100% of the MIPS eligible clinicians in the group qualify as individuals for any reason.
If you don’t qualify for PI to be automatically reweighted, you can apply to CMS to obtain an exemption from the PI category due to a “significant hardship”. If you are in a small group (15 or fewer clinicians), you can apply for the PI Hardship Exception directly in your MDinteractive account. More information about the Hardship Exception can be found on our website here. The deadline to submit applications to CMS is December 31, 2020.
Applications must be based on one of the following reasons*:
- MIPS eligible clinician in a small practice (15 or less providers in the TIN)
- Insufficient Internet connectivity
- Extreme and uncontrollable circumstances:
- Practice or hospital closure
- Severe financial distress resulting in bankruptcy or debt restructuring
- Vendor issues (such as a change in vendors during the performance period or errors with your CEHRT that your vendor is unable to address)
- Lack of control over the availability of CEHRT
- EHR Decertification
*CMS has indicated that simply lacking CEHRT is not sufficient to qualify for reweighting.
Important: MIPS eligible clinicians and groups that qualify for reweighting will be scored in this performance category if they submit any PI data.
If you plan to attest to PI this year, the first step is to ensure you have 2015 Edition CEHRT by checking your certification here. You may want to consider running a trial report in your EHR of the 2020 PI measures and understand how you are performing in each area since it will impact your score. We understand this issue is complex, so our MIPS specialists can help if you have questions about the requirements or how you can maximize your MIPS points in this category.
MACRA MIPS Promoting Interoperability PI Scoring 2015 Edition CEHRT