1. 2019 MIPS Promoting Interoperability
Reporting Guide for CRNAs
The AANA Research and Quality department prepared this is a brief overview of MIPS Quality performance category in 2019, as it applies to CRNAs who are eligible to participate in MIPS. This is Year 3 of the MIPS program.

2. MIPS Reporting Categories
Quality
Improvement Activities (IA)
Promoting Interoperability (PI)*
Cost
*CRNAs are subject to automatic re-weighting for the PI category. Reporting this category is voluntary.
CRNAs are listed as a clinician type that is subject to an automatic re-weight for the PI measure category, so that it is not required for MIPS reporting.
08FEB2019

3. Promoting Interoperability Category
45% final Score
(for CRNAs reporting PI* with applicable Cost Measures)
70% final Score
(for CRNAs NOT reporting PI*, but with applicable Cost Measures)
85% of final score
(for CRNAs NOT reporting PI* with NO applicable Cost Measures)
*PI – Promoting Interoperability
This illustrates the weights of each performance category in relation to the MIPS Final Score, which is calculated as percentage. The categories can be re-weighted based on applicability of the Promoting Interoperability and Cost Measures. The first chart shows the weight of the Quality category at 45%, when a provider reports all four MIPS categories; 70% when reporting three categories (no PI); and 85% when reporting Quality and IA only. No PI or Cost measures. If a group reports PI, all MIPS ECs must qualify for re-weighting. Groups designated as non-patient facing are not automatically eligible to have their Promoting Interoperability performance category reweighted to 0%.
08FEB2019

4. Promoting Interoperability Performance Category
Promotes patient engagement and the electronic exchange of health information using Certified Electronic Health Record Technology (CEHRT)
Participation requires use of 2015 edition CEHRT
Clinicians including CRNAs can participate as individuals or in groups
Data is collected for a minimum of any 90-day continuous period within a calendar year (January 1st through December 31st)
Group must include at least one MIPS eligible clinician. Groups designated as non-patient facing are not automatically eligible to have their Promoting Interoperability performance category reweighted to 0%.The latest a provider could report for a 90-day period in 2019 would be October 3rd. ECs can utilize CEHRT that is not approved at the beginning of the performance period, but is approved by the end of that period.
08FEB2019

5. Participation Requirements for PI
Eligible clinicians must complete the Security Risk Analysis measure
Submit a “yes” to the following attestations:
Prevention of Information Blocking
ONC Direct Review Attestation
Completion of
Measure data must be collected from CEHRT for all patients
Attestation is a legal term, confirming that something is true or accurately represents facts—in this case that the CEHRT is being used for specified purposes.

6. Participation Requirements for PI (cont.)
Eligible clinicians report applicable measures from 4 objectives in the PI Performance Category:
There are a total of 11 measures available from 4 measure category objectives. At least 1 case in numerator to report a PI measure.

7. Hardship Exceptions to PI Category
Insufficient internet connectivity
Extreme or Uncontrollable Circumstances: disaster, practice closure, severe financial distress, vendor issues
Use of decertified electronic health information technology
Small practice
In addition to automatic re-weights, there are hardship exceptions to reporting PI. Clinicians must apply for hardship exception by December 31, 2019.

8. Public Health and Clinical Data Exchange
ECs must participate in two different registries to receive a score for this objective
Providers can select:
Immunization Registry Reporting
Electronic Case Reporting
Public Health Registry Reporting
Clinical Data Registry Reporting
Syndromic Surveillance Reporting
Providers can report the same measure twice if active with two different agencies or registries.

9. Reporting PI Data – Submission Types
For group reporting, data for each clinician should be combined under one TIN. Included are those clinicians who otherwise would be eligible for automatic re-weight as individuals.

10. Promoting Interoperability Category Scoring
Measure achievable points are between 1 and 10 per measure
ECs can earn up to 100 points for the PI measure set
The total measure achievable points are divided by the total possible points for the performance category score
Clinicians can receive 5 bonus points for each optional PI measure reported:
Query of Prescription Drug Monitoring Program (PDMP)
Verify Opioid Treatment Agreement
The total points are divided by total possible points. That percentage is then multiplied by the 25% performance category weight.

11. Example of Promoting Interoperability Category Score
The performance rates, and PI category weight is rounded to the nearest whole number

12. Additional Resources
Quality Payment Program website:
QPP Resource Library:
Promoting Interoperability Fact Sheet
Technical Assistance:
Phone: (Monday through Friday)
CMS offers resources in print, video and webinars to assist you with 2019 MIPS reporting requirements.