Under the Merit-Based Incentive Payment System (MIPS), part of the Quality Payment Program (QPP) created under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), clinicians will be required to meaningfully use certified electronic health record (EHR) technology. Under the new program, the EHR component is referred to as Advancing Care Information (ACI), which replaces the Medicare EHR Incentive Program
ACI expands health IT use requirements beyond physicians to other eligible clinicians, including nurse practitioners, physician assistants, clinical nurse specialists and certified registered nurse anesthesiologists in 2017 and 2018. Only physicians were required to meaningfully use EHRs under the EHR Incentive Program. The Centers for Medicare and Medicaid Services (CMS) has proposed expanding the category of eligible clinicians to include physical and occupational therapists, audiologists, nurse midwives, clinical social workers and nutrition professionals for 2019. A decision regarding this proposed second expansion will be made at a later date.
All MIPS-eligible clinicians will be able to participate as individuals or as members of a group.
Objectives and Measures
In 2017, clinicians have three options for reporting based on the edition of certified EHR technology in use:
- Use 2014 edition certified technology and report on the 2017 ACI Transition measures.
- Use a combination of 2014 and 2015 edition certified technology and report on both the ACI Transition measures and the ACI measures.
- Use 2015 edition certified technology and report on the ACI measures
Beginning in 2018, clinicians must use 2015 edition certified technology only to report on the ACI objectives and measures.
While the ACI performance category of MIPS reporting requirements are somewhat different than those established in the 2015 Medicare and Medicaid EHR Incentive Programs, they do borrow heavily from the previous programs.
In 2017, the ACI category accounts for 25 percent of the MIPS total score. The ACI score consists of a base score, a performance score and a possible bonus score.
To receive the base score of 50 points for the ACI category, clinicians will report data for the following five required measures:
- Performing a Security Risk Analysis
- Providing Patient Access to Their Data
- Sending Summary of Care via Health Information Exchange
- Requesting/Accepting Summary of Care
If even one is missed, clinicians will earn a 0 for the entire ACI category of the MIPS Composite Score. This is in contrast to the 20 measures required under the Medicare EHR Incentive Program.
Eligible clinicians can earn additional points based on their performance on measures that comprise the following four objectives:
- Patient Electronic Access
- Coordination of Care Through Patient Engagement
- Health Information Exchange
- Public Health Reporting
Because the maximum point total for the ACI component of the MIPS Composite Score is capped at 100 points, clinicians have some flexibility to focus only on some of the measures attributable to the performance score.
An eligible clinician can earn bonus points by completing additional measures under the Public Health and Clinical Data Registry Reporting objective, such as reporting to a specialized registry (i.e., the PINNACLE Registry) or using certified EHR technology to complete certain activities in the Improvement Activities category, such as managing referrals and consultations. These bonus points will be added to the clinician’s ACI score after calculation of the performance score.
Other Health IT Requirements
In addition to the ACI component of MIPS, there are two additional requirements for clinicians and hospitals.
Clinicians and hospitals must cooperate with any activities conducted by the Office of the National Coordinator for Health IT (ONC) pertaining to health IT surveillance and oversight activities regarding the performance of the certified EHR technology in use by the clinician. These surveillance and oversight activities include responding to requests for information from ONC in a timely manner and facilitating onsite review of certified EHR technology.
Clinicians and hospitals are also required to attest that they have not knowingly and willfully taken action to limit or restrict the compatibility or interoperability of certified EHR technology.
With the exception of the ONC surveillance and information blocking requirements, these changes do not apply to hospitals or critical access hospitals that remain under the federal EHR Incentive Programs.
2018 Payment Adjustment
At present, clinicians who have not successfully demonstrated meaningful use through the EHR Incentive Program in a prior year and are reporting for the EHR Incentive Program the first time in 2017 will be subject to a payment adjustment in 2018. As part of the Hospital Outpatient Prospective Payment System (OPPS) rule, CMS finalized that such clinicians have until Oct. 1, 2017, to attest to meeting those requirements to avoid the 2018 payment adjustment.
CMS created a new hardship exemption for eligible clinicians who are new participants in the EHR Incentive Program beginning in 2017 and want to avoid penalties. This exemption applies to clinicians that have not demonstrated meaningful use in a prior year, intend to attest to meaningful use by Oct. 1, 2017, and will be transitioning to the MIPS program.
Quick Tips to Prepare for Advancing Care Information
- Review ACC and CMS Quality Payment Program resources and participate in educational sessions.
- Determine the status of your current EHR Incentive Program participation.
- Decide if you will be implementing new EHR technology, or readying existing technology to meet the MIPS objectives and measures for ACI.
- Evaluate if your organization is meeting the current objectives and measures using this comparison table.
- Enroll in the PINNACLE Registry and qualify for a Public Health Registry Bonus Point on your total ACI Performance Category Score.