Note: This article has been updated to reflect the 2017 Final Rule released by CMS.
***IMPORTANT: CMS has renamed the ACI performance category of MIPS to Promoting Interoperability (PI) beginning with the 2018 MIPS reporting year. An article about the 2018 PI performance category requirements is currently being developed. Please email email@example.com for questions and guidance in the meantime. ***
Advancing Care Information (ACI) is one of the three performance categories scored this year under the Merit-Based Incentive Payment System (MIPS). Below are six things to know about this category in order to prepare for 2017:
1. ACI Replaces the Medicare EHR Incentive Program for Eligible Professionals
MIPS-eligible clinicians (ECs) are no longer required to participate in the Medicare EHR Incentive program (Meaningful Use, or MU). Instead, they will earn points toward their MIPS Final Score by attesting to measures in this new category related to the meaningful usage of their EHR. The State-level Medicaid programs are still in effect, however, and some states allow clinicians to participate in both MIPS and Medicaid MU. Because there are still incentive dollars in some of those programs, it is a good idea to check with your local DHHS office for more details.
2. 2017 is a “Transition Year”
Medicare has made 2017 a Transition Year for providers to get started with MIPS. One way to avoid a penalty is to submit just the base measures in the ACI category. To earn an incentive, you must report on all four of the transition measures in this category for 90 days.
3. The Categories for the Measures Should Look Very Familiar
There are four transition measures required to earn 50% of the total available points in the ACI category. This is called the “base score”. To report on these measures, you indicate “yes” or a numerator of at least “1.” These measures include:
- Security Risk Analysis
- Electronic Prescribing
- Provide Patient Access
- Send a Summary of Care
In addition to the measures reported for the base score, there are additional performance measures that will increase your overall ACI score. Your score increases the higher the performance percentage for the following:
- View, Download or Transmit
- Patient-Specific Education
- Secure Messaging
- Medication Reconciliation
Double performance points will be then added for two of the originally required measures, meaning that if you perform well in these two measures, you have the ability to “make up” points for low performance on others:
- Provide Patient Access
- Send a Summary of Care
Finally, you can earn bonus points for reporting these measures:
- Immunization Registry
- Syndromic Surveillance Reporting
- Specialized Registry Reporting
Some of the improvement activities allow you to also earn ACI bonus points if you attest to those improvement activities using Certified EHR Technology (CEHRT). These activities display an “ACI Bonus” checkmark in the IA section of the Mingle Portal.
4. The Scoring Provides Flexibility to Earn a Maximum of 100 Points, Which Will Count for 25% of the Final Score
5. There Are Special Considerations and Hardship Exemptions for This Category
MIPS Eligible Clinicians may also file for hardship exceptions from the ACI category only. If accepted, this means they would not need to report ACI category data and the 25% allotted to the ACI score would be re-weighted to the Quality category instead. There are three categories provided for clinicians to apply against:
- Insufficient Internet Connectivity
- Extreme and Uncontrollable Circumstances
- Lack of Control over the Availability of CEHRT
If a MIPS Eligible Clinician falls into one of the following special statuses, this will be seen on the QPP website when entering that clinician’s NPI into the QPP NPI Lookup. These special status clinicians will not be expected to submit ACI data, and the ACI points will be re-weighted to the Quality category without the need for a hardship application.
Note: If a Special Status Clinician submits ACI data to CMS regardless of their special status, CMS will score those measurements as if the clinician was not ACI exempt.
- Hospital-based clinicians
- Physician Assistants
- Nurse Practitioners
- Clinical Nurse Specialists
- Certified Registered Nurse Anesthetists
- Non-Patient Facing Clinicians
6. Incentives Are Within the Reach of Many
The Transition Year means a reduced reporting burden for providers. However, for practices experienced with MU, ACI should be very familiar and easier. Because of this, providers and practices have a great chance of succeeding in this category.
To learn more about this category or how you can succeed with MIPS, contact one of our friendly consultants.
Dr. Dan Mingle and members of the team share their insights on how to maximize your success and payments for MIPS and APMs.