MIPS 2020 Final Rule: Promoting Interoperability Category

The Promoting Interoperability category is aimed at promoting patient engagement and the electronic exchange of information through CEHRT (certified electronic health record technology). Practices and eligible clinicians reporting for the Merit-based Incentive Payment System (MIPS) must report a minimum of 90 days for this category, although longer periods, including a full year, can be submitted.

The category weight remains unchanged for 2020 at 25 percent of the total MIPS score. Practices must be using a 2015 CEHRT functionality from the first day of the performance period. It also must be certified by the ONC by the last day of your performance period. Also required for your submission is your EHR’s CMS identification code from the Certified Health IT Product List (also referred to as certification ID), which can be found at https://chpl.healthit.gov/#/search.

The Centers for Medicare & Medicaid Services (CMS) will allow some hardship exemptions for certain circumstances (uncontrollable circumstances, lack of internet availability, small practice and decertified EMR – for five years only), but practices must apply for the exemption by December 31 and be approved by CMS. If approved, the Promoting Interoperability points will be reweighted to the Quality category.

The objectives and measures are similar to previous years, but the Verify Opioid Treatment Agreement which was considered for bonus in 2019 was removed. As in previous years, practices must conduct or review a Security Risk Analysis within the performance year. While it does not count toward points, if your practice has not completed this task, you will not be able to submit data for this performance category.

The Query of Prescription Drug Monitoring Program (PDMP) will continue to be optional for reporting, but as a yes/no response, it does offer practices five bonus points in the category.

Groups or Virtual Groups will qualify for automatic reweighting when 75 percent of the eligible clinicians in the reporting group are hospital based.

For 2020 MIPS reporting, CMS will calculate your score for the Promoting Interoperability category based on data of at least a minimum of a 90 consecutive day period, counting toward 25 percent of your MIPS final score. Practices must:
  • Use a 2015 CEHRT.
  • Meet the four objectives. Within these objectives there are six required measures in addition torequired attestations.
  • Conduct or review a Security Risk Analysis.

Information for this article was taken from the MIPS 2020 Final Rule webinar presented in January by the Quality Reporting Engagement Group. The team is ready to help practices with all your MIPS needs, from submission assistance for 2019 reporting to a full-service consulting partnership for 2020. Contact them at sales@intrinsiq.com.

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