Promoting Interoperability MIPS Performance Category Overview
Introduction
CMS has renamed the Advancing Care Information performance category of MIPS. It is now called Promoting Interoperability. This page will provide an overview of this category and links to additional more detailed information.
Promoting Interoperability replaces the Advancing Care Information performance category of MIPS and is the new name for other CMS programs formerly referred to as the meaningful use of Certified PHR Technology.
The Promoting Interoperability category is weighted at 25% of the total MIPS score in 2017 and 2018. CMS can reduce the weighting of this category to as low as 15% in future years based on the level of electronic health record usage by MIPS participants.
In the 2018 Quality Payment Program final rule CMS stated they anticipated that the vast majority of practices would achieve a 100% score in this category. For example, just meeting the minimum requirements under the meaningful use of Certified PHR Technology would have achieved a score of 89 percentage points. Nearly all practices that make a good faith effort to perform in this category should be able to achieve a 100% score. However, certain steps need to be taken.
2018 Promoting Interoperability Measures and Objectives
In 2018 there are two sets of measures that can be reported based on the certification edition of the EHR that is being used by the practice:
- 2018 Promoting Interoperability Transition Objectives and Measures – used for reporting when the practice is using “2014 Edition” Certified EHR Technology. This option will not be available starting in 2019. All practices will need to upgrade to the 2015 Certified EHR Technology edition.
- Promoting Interoperability Objectives and Measures – these measures are used when the practice is using “2015 Edition” Certified EHR Technology.
In 2018 all practices will be allowed to submit the 2018 Promoting Interoperability Transition Objectives and Measures, whether they are using 2014 or 2015 edition Certified EHR Technology, or combination of the two.
Bonus for using 2015 Edition Certified EHR Technology
In 2018 individual clinicians and groups that exclusively report the Promoting Interoperability Objectives and Measures (i.e., they must be using 2015 edition Certified EHR Technology for the entire reporting period) will receive a 10% bonus on their Promoting Interoperability performance score.
Promoting Interoperability Reporting Period
The Promoting Interoperability reporting period in 2017, 2018 and 2019 is a continuous 90 days during the performance year. Practices may report data as late as between October 3, 2018 and December 31, 2018 to meet this requirement.
A 90 day reporting period for 2019 was finalized in the 2018 Quality Payment Program Final Rule. This is important as it gives practices using 2014 Edition Certified EHR Technology an addition 9 months in 2019 to upgrade to 2015 Edition Certified EHR Technology.
Promoting Interoperability Scoring
Promoting Interoperability scores are the sum of three scores:
- Base Score: 50%
- Performance Score: up to 90%
- Bonus Score: up to 25%
All measures and objectives in the base score are mandatory. If all of their requirements are not met the individual clinician or group will receive zero points for the entire Promoting Interoperability performance category.
The Performance Score measures are not mandatory for reporting, but performance on these measures can reach total of up to 90 points. Regardless of the total number of points attained, however, CMS will cap score at 100 points. Once 100 points have been achieved the practice will receive the full 25 points towards their total MIPS score.
An additional 25 points in this category is available as bonus points.
Scores as high as 165 points could be attained in this category, however, as noted above, scores between 100 and 165 points will yield the exact same performance for the Performing Interoperability performance category of MIPS, i.e., they will receive the maximum points in this category.
The base, performance and bonus measures for practices reporting the 2018 Promoting Interoperability Transition Objectives and Measures (i.e., those using 2014 edition Certified EHR Technology) are available here.
The base, performance and bonus measures for practices reporting the Promoting Interoperability Objectives and Measures (i.e., those using 2015 edition Certified EHR Technology) are available here.
Promoting Interoperability Category Reweighting
The Promoting Interoperability performance category may be weighted to 0% in certain circumstances, such as when the clinician is not a physician or when the clinician is hospital or ambulatory surgery center based. Additional re-weightings are available for clinicians in small practices, those using decertified use our technology, those with insufficient Internet connectivity, those who have experienced extreme and uncontrollable circumstances, and clinicians to do not have control over whether Certified EHR Technology is available.
However, if the Promoting Interoperability performance category is related to 0% the 25% weighting of MIPS will shift to the quality category. In 2018 quality is weighted at 50% so this will increase its weighting to 75%.
Additional details on re-weighting of the Promoting Interoperability performance category is available here.