October 3, 2019 marks the last day to start the 90-day Performance Period for Promoting Interoperability and Improvement Activities. Previously known as Advancing Care Information, Promoting Interoperability Requirements counts for 25% of the total quality score for the year.

Let’s go back, The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), also known as Medicare Quality Program was designed to replace the Sustainable Growth Rate (SGR) formula. In other words, rather than implementing a standard cut in Medicare rates across the board, MACRA provides the opportunity to receive a decrease or increase in the Medicare fees of the provider based on their own performance.

Promoting Interoperability is one of the four performance categories of Medicare’s Quality Program (MACRA), and as mentioned before, the score counts for 25% of the total accumulated score for the year.

In this case, clinicians must collect data for a minimum of a 90-day continuous period in order for them to meet this measure, hence, the last day to start collecting data for 2019 is October 3.

In addition to submitting the applicable measures, clinicians must answer “yes” to:

• The Prevention of Information Blocking Attestation,
• The ONC Direct Review Attestation, and;
• The security risk analysis measure.

Note: submitting a “yes” without performing the above actions is fraud and if caught you may face mandatory fines, civil and criminal charges.

Bottomline, make sure to start collecting data and schedule your HIPAA Security Risk Analysis as soon as possible.