The Centers for Medicare & Medicaid Services (CMS) is proposing a redesign of incentives under the Merit-Based Incentive Payment System (MIPS) as part of the 2019 Updates to the Quality Payment Program (QPP). This affects Medicare eligible clinicians participating in the “Promoting Interoperability” (formerly Advancing Care Information) performance category of the MIPS.

The proposed redesign is in line with the overall goal of the MyHealthEData Initiative, which involves the promotion of the interoperability of electronic medical records by breaking down barriers that prevent patients from having electronic access to and control over their health records, in addition to keeping their information safe and secure. Under the proposed rule, CMS is renaming the advancing care information MIPS performance category to Promoting Interoperability (PI). The name change reflects the focus on interoperability and improving patient access to health information when measuring meaningful use of EHR.

Beginning with the 2019 MIPS Performance period, CMS is requiring MIPS eligible clinicians to use 2015 Edition certified EHR technology, thus eliminating the option of using the 2014 Edition. CMS believes the requirement is necessary as the health information technology (IT) industry has evolved, rendering the 2014 Edition out of date and insufficient to meet the needs of clinicians. The 2015 Edition better aligns with the overall goal of improving interoperability and patient access and control to their health records. Unlike the legacy systems, the 2015 Edition offers more interoperability features and requirements such as Application Programming Interface (API) functionality and capabilities to export patient data. By requiring the 2015 Edition, there will be a reduced burden across many settings. For example, Health IT developers can focus resources on developing products that comply with one edition of certification requirements. Additionally, MIPS eligible clinicians will no longer have to certify legacy systems and can improve patient care across the continuum through the more comprehensive functions offered by the 2015 Edition.

In addition to the CHERT requirements, CMS is proposing a new scoring methodology in the Promoting Interoperability performance category for MIPS eligible clinicians. CMS intends to move away from the base, performance, and bonus score methodology that is currently used. The proposed scoring methodology includes a combination of new measures broken into a smaller set of four objectives and scored based on performance, thus eliminating the concept of base and performance scores. The new scoring methodology is intended to provide clinicians with more flexibility to perform on measures that are applicable to them, focus on patient care and health data exchange, and align the PI performance category requirements for clinicians with the Medicare Promoting Interoperability Program (PIP) requirements for hospitals.

CMS has also considered alternative approaches to revising the scoring system which is set forth in detail in the proposed rule. They are seeking public comment on this alternative approach as well as promoting interoperability and electronic healthcare information exchange through possible revisions to the CMS patient health and safety requirements. Public comments are due no later than 5 p.m. on September 10, 2018.