In 2017, most healthcare organizations were very familiar with the Advancing Care Information (ACI) category under the Merit-based Incentive Payment System (MIPS). And we became very familiar with the ACI acronym. Fast forward to 2018. CMS has changed the name of this category to Promoting Interoperability (PI), which actually makes a lot of sense based on CMS' vision of interoperability, improved flexibility, and less burden.
Promoting Interoperability Facts
- In 2018, the Promoting Interoperability category will make up 25% of the final score. There are a few exceptions that could change this percentage:
- Special Statuses such as small practice, non-patient facing, health professional shortage area, and others.
- Hardship exceptions MIPS eligible clinicians and groups may qualify for a reweighting of their promoting interoperability category score, which would shift the 25% to the quality performance category.
- APM Participation.
- MIPS participants who do not meet one of the exceptions above should submit collected data for 4 to 5 Base Score measures for 90 days or more during 2018.
- Like 2017, this year participants will be required to attest to the following statements: "Prevention of Information Blocking Attestation," and "ONC Direct Review Attestation."
- There are 22 Promoting Interoperability Measures. As far as what documentation will be necessary for these measures remains to be seen: "specifications files per measure will be available Summer 2018.
- There will be 4 ways for participants to submit data: attestation in the QPP data submission system; Electronic Health Record (EHR); Qualified Clinical Data Registry; Qualified Registry.
Healthcare Compliance pros will be providing updates as we learn of them. In the meantime, our recommendation for eligible clinicians who participated last year is to continue your efforts in 2018. We were pleased to learn how well MIPS participants who worked on their Advancing Care Information measures throughout their year did in 2017. We expect the same will be true for eligible clinicians in 2018, under the updated Promoting Interoperability category.