Changes in the MIPS 2019 Proposed Rule: Promoting Interoperability

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The Centers for Medicare & Medicaid Services (CMS) recently issued its Proposed Rule for 2019 under the Quality Payment Program. In this week’s blog we examine changes in the Promoting Interoperability (formerly Meaningful Use and Advancing Care Information) performance measure category. 

CMS has proposed several changes to the Promoting Interoperability category for 2019, including significantly reducing the number of measures that are available. It is expected that the proposed changes will make it more difficult for practices to achieve the full 25 points in this category.
As an example, to earn the full 25 points for the category in 2018, practices or eligible clinicians need to earn 100 out of 165 points available. In 2019, only 110 total points are available in the category, and that includes a 10-point bonus if you are able to report on a new measure and EPCS (Electronic Prescriptions for Controlled Substances) is available in your state. The following year, 2020, practices will have to earn the entire 100 total points in the category to gain those 25 composite points.
The measures proposed for removal in this category include:

  • Patient-specific Education
  • Secure Messaging
  • View, Download and Transmit
  • Patient-generated Health Data
  • Clinical Information Reconciliation*
  • Request/Accept Summary of Care*

(*These last two measures will be combined into a new category called Support Electronic Referral Loops Receiving and Incorporating Health Information.)
More emphasis will be placed on the issue of prescription drug abuse. New measures to address those include Query of Prescription Drug Monitoring (PDMP) and Verify Opioid Treatment Agreement. Practices will be excluded from reporting on these measures if the practice or provider cannot e-prescribe Schedule II opioids.
In addition, a Security Risk Analysis is not a scored measure, but it still will be required to achieve any points in this category.
Practices will have to report a minimum of 90 days up to the full calendar year for 2019 measures and will be required to use the 2015 Edition CEHRT. The 2014 Edition will not be an option.
Keep in Mind:

  • The reporting period is a minimum of 90 days.
  • Claiming exclusions does not always help you. If you can meet the measure, that will help your score.
  • Be prepared to use secure transmission methods to send and receive referrals. Check with other providers involved in your patient’s care to understand their methods so you are prepared to accept and send.
  • Check with your EHR vendor on available transmission methods; PDMP and Opioid Agreement verification for those bonus points; and EPCS, if allowed in your state. 

The comment period for the 2019 Proposed Rule closed in September. We expect the Final Rule on the proposals above to be released in November.
If you have additional questions about the 2019 Proposed Rule or questions about MIPS reporting, contact the Quality Reporting Engagement Group at

This information was taken from the InfoDive Coding and Audits webinar held in November 2018.