MIPS Promoting Interoperability - Unique Challenges in 2019

Date: Friday September 20, 2019

10:00 AM PDT | 01:00 PM EDT

Duration: 60 Minutes
Instructor: Michael Stearns
Webinar Id: 801810
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This presentation will review the 2019 changes to Merit-based Incentive Payment System (MIPS) and the challenges that have been created. It will also identify strategies that will lead to higher levels of performance.


The EHR incentive program provided significant incentives to clinicians to adopt certified electronic health record technology. However, one of the major elements of this program is a continuing lack of interoperability. For this reason, CMS has placed an emphasis on true connectivity between organizations.

CMS is also removed redundant points that allowed professionals to reach the target goal of 100 points fairly easily. In 2019, the redundant points have been eliminated, meaning that each time performance is not met for a measure it will negatively impact the final score.

Two of the measures in particular have high weightings and together make up 40% of the Promoting Interoperability performance score. These are the measures in the Health Information Exchange category of the promoting Interoperability performance score, titled "Support for Electronic Referral Loops by Sending Health Information"and another measure titled "Support for Electronic Referral Loops by Receiving and Incorporating Health Information."Each time the clinician fails to send a summary care document during and outbound transition of care or fails to incorporate a summary care document into their EHR for an inbound referral they will lose points in these two measures. The requirements as stated in the specification documents lack clarify and completeness. We have been working with CMS Quality Payment Support to get a clear understanding of how these measures should be scored.

In many cases there appears to be missing or ambiguous information in the available specification documents and making decision based on what is available form CMS alone could lead to reporting errors.

Practices have the option of applying for Hardship Exceptions for the Promoting Interoperability performance category, but there are several things to document and store to protect against future audits.

CMS is also made it mandatory in 2019 that the EHR and all modular components that work with the EHR and that engage with any of the Promoting Interoperability performance measures need to have undergone 2015 edition certification.

This presentation will review the 2019 changes and the challenges that have been created. It will also identify strategies that will lead to higher levels of performance.

Why should you Attend: Not understanding the key elements of the MIPS Promoting Interoperability performance category could result in practices losing 25% of their MIPS score. Major changes to the structure and how points are earned will prevent the vast majority of users to achieve high scores in 2019.

The requirements provided by CMS are relatively ambiguous and require direct engagement with CMS representatives to understand which patients should be included in the denominator and which of these should be included in the numerator (i.e., as "performance met." Not understanding these requirements could lead to inaccurate reporting.

For example, each time a clinician sends a patient to another facility or provider in a transition of care or as a referral the receiving party must be able to receive the message electronically via a secure format.

Performance on this measure may be out of the control of the practice, but there is still time to established networks in your community.

MIPS audits have started this year, and practices need to understand detailed CMS guidance in order to be compliant and avoid penalties. We have spent a great deal of time studying the requirements and requesting clarifications from CMS.

In many instances the requirements as stated in MIPS materials could be easily misinterpreted. We have also spent a great deal of time evaluating the PI Hardship Exceptions and will walk attendees through how to understand if your practice is eligible, and if so what documentation you will need to produce in the case of a future audit.

Areas Covered in the Session:

  • Review of the Promoting Interoperability performance category
  • Review of the Promoting Interoperability Hardship Exceptions
  • A detailed review of each Promoting Interoperability measure, including clarifications from CMS
  • Potential challenges associated with performance in this category
  • Recommendations

Who Will Benefit:
  • Physicians and other Clinicians in Organizations Engaged in the MIPS
  • Informatics Professionals
  • Compliance Officers
  • Health Information Technology Professionals
  • Health Information Exchange Professionals
  • Health IT Vendors

Speaker Profile
Michael Stearns, MD, CPC, CFPC, is a physician informaticist, certified professional coder (CPC), certified family practice coder (CFPC). He is the CEO and Founder of Apollo HIT, LLC, an Austin-based company that provides consulting services in the areas of healthcare information technology and compliance. His company assists organizations with meeting their documentation, coding, EHR optimization and program goals, including their performance in the Merit-based Incentive Payment System and Alternative Payment Models.

During his career Dr. Stearns has received several awards for teaching and contributions to patient safety and patient privacy initiatives. He played a central role in the design and development of vocabularies at the National Institutes of Health (NIH) and provided a leadership to the development of the Systematized Nomenclature of Medicine - Clinical Terms (SNOMED CT). He has served in a leadership capacity for two leading EHR vendors and as an advisor to several emerging HIT organizations.

He is a cofounder and lecturer at the University of Texas at Austin Health Information Technology Certificate Program, a nationally recognized model for HIT workforce development. He has been invited to testify in Washington, D.C. before federally sponsored HIT policy and standards organizations on five separate occasions. He served as the founding board president of the Texas eHealth Alliance, an organization that provides stakeholder input related to health information technology policy matters to state legislators. He is also an accomplished author and lecturer on a range of health care quality, health information technology, coding/compliance and quality-based performance initiatives.

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