By David Thill
New EHR reporting program accommodates practices’ unique patient populations.
MACRA – the Medicare Access and CHIP Reauthorization Act of 2015 – replaces the Medicare Sustainable Growth Rate (SGR) with the Quality Payment Program (QPP), in an effort to emphasize the quality – over quantity – of services provided to patients. (Read Repertoire’s February issue for an overview of the law.)
The QPP, open to qualifying clinicians, is divided into two paths, of which clinicians must take one. One of these paths is the Merit-based Incentive Payment System, or MIPS.
Within MIPS, quality accounts for the biggest portion of data (60 percent) that physicians must report to the Centers for Medicare and Medicaid Services for reimbursement. That quality component was the subject of Repertoire’s April MACRA segment.
This month, Repertoire focuses on another component of MIPS: Advancing Care Information, or ACI. At 25 percent, ACI is the second largest component of MIPS on which physicians must report data to CMS. Here is a summary of what it entails.
ACI
“Advancing Care Information,” or ACI, replaces the Medicare EHR (electronic health record) Incentive Program, also known as Meaningful Use. While certain key aspects of ACI resemble those of Meaningful Use – including the fact that care providers must use a certified EHR technology to report data – the new system is different in a few key ways, says Steven Waldren, M.D., director of the Alliance for eHealth Innovation at the American Academy of Family Physicians.
First of all, says Waldren, physicians have significantly less data they have to report to CMS under ACI than they did under Meaningful Use. Depending on their EHR technology, doctors have 4-5 required measures on which to report for their “base score.” This base score is worth 50 percent of the final ACI score. Without that 50 percent (see below for more information about how it is calculated), providers will receive a “zero” for the ACI portion of MIPS. (Remember that ACI is part of a larger MIPS score.)
Providers can also earn additional points for reporting on optional measures beyond the base score. These additional measures comprise the “performance score.” One important note on the performance score: Some of the required measures used to obtain the base score are also counted in the performance score.
The base score and performance score are then added together, along with an additional “bonus score,” to determine a provider’s final ACI score. Clinicians can earn bonus points in two ways:
- By reporting “yes” to one or more additional public health and clinical data registries beyond the “Immunization Registry Reporting” measure.
- By reporting “yes” to the completion of at least one of the specified Improvement Activities using CEHRT (certified EHR technology). The Improvement Activities – along with ACI, Quality, and Cost – are another part of the MIPS component of MACRA, and will be featured in a future issue of Repertoire.
Out of a total 155 points available – for the added base score, performance score, and bonus score – 100 or more is considered a perfect score. This offers doctors “wiggle room,” says Waldren, so they can tailor their reporting priorities to their patients.
For example, he says, some doctors work with a predominantly elderly patient population whose members may have less interest in communicating with the doctor via direct electronic message. (“Secure Messaging” is one of the optional measures on which physicians can report for their performance score.) So, those doctors might work to maximize a different measure to boost their score and earn higher CMS reimbursement.
Four or five measures?
The number of required measures physicians report on depends on whether they choose to report using the “Advancing Care Information Objectives and Measures” option, or a transition option, “2017 Advancing Care Information Transition Objectives and Measures.” This all depends on the year for which their EHR is certified.
Anyone can choose to report under the transition option, says Waldren. In order to report under the non-transition option – “Advancing Care Information Objectives and Measures” – doctors’ EHR technology must be certified to the 2015 edition, or else use a combination of technologies from the 2014 and 2015 editions that support the measures. (After this year, all providers will report under the non-transition option.)
The main difference between the two options is that the transition one has 11 measures on which doctors can report, while the non-transition one has 15 measures. This is simply because older EHR editions (whose users must opt for the transition option) cannot technically support certain measures.
The transition option has a required four measures on which providers must report. Three of those measures – and an additional two others – are required for physicians to report on under the non-transition option, for a total of five.
So, what are the measures?
The required measures
The four required measures that physicians must report on under the transition option to receive their base score are:
- Security Risk Analysis
- e-Prescribing
- Provide Patient Access
- Health Information Exchange
The five required measures for the base score for physicians who report under “Advancing Care Information Objectives and Measures” (the non-transition option) are:
- Security Risk Analysis
- e-Prescribing
- Provide Patient Access
- Send a Summary of Care
- Request/Accept Summary of Care
To receive the necessary 50 percent base score, clinicians must report a “yes” for the Security Risk Analysis. Additionally, for the rest of the required measures, which are reported in a numerator/denominator fashion, clinicians must report at least a 1 in the numerator to receive the 50 percent base score.
The “Security Risk Analysis” is already an annual requirement for physicians to perform under HIPAA, says Waldren. So, he says, that one was a “no-brainer” for CMS to require. He adds that e-prescribing is already a common practice among doctors, too.
A binding factor among all of these required measures is “interoperability,” he adds: Physicians must be able to perform appropriate transitions of care for patients from one location to another.
The other binding factor is an effort to provide patients with access to their electronic records, says Waldren. Doctors can do so either by creating an online patient portal, or (if their EHR is certified for 2015) by allowing patients access to their API (application programming interface).
Though physicians have fewer measures on which they can report under the transition year option, CMS makes up for the difference by weighing certain measures more under that option than under the non-transition option. For example, “Provide Patient Access” accounts for up to 20 percent of physicians’ performance score from CMS under the transition option, as opposed to only 10 percent under the non-transition option.
As Waldren observes, ACI is “pretty complex.” That said, he believes the new system is an improvement on the old one.
Visit https://qpp.cms.gov/docs/QPP_ACI_Fact_Sheet.pdf for an ACI fact sheet. Visit qpp.cms.gov to learn more about ACI, MIPS, and the Quality Payment Program in general.
Advancing Care Information measures
Under the Advancing Care Information, or ACI, portion of MIPS, eligible clinicians receive a score of up to 100, most of which is obtained by reporting data on a set of measures. The measures on which clinicians report differ slightly based on whether they choose a transition option – “2017 Advancing Care Information Transition Objectives and Measures” – or a non-transition option – “Advancing Care Information Objectives and Measures.” The option they choose depends on the year from which their EHR technology is certified.
Here is a list of the measures on which clinicians can report for each option. Some, denoted by an asterisk (*), are required, accounting for a “base score” portion of the final score:
Non-transition: “Advancing Care Information Objectives and Measures”
- Security Risk Analysis*
- e-Prescribing*
- Provide Patient Access*
- Send a Summary of Care*
- Request/Accept Summary of Care*
- Patient-Specific Education
- View, Download and Transmit (VDT)
- Secure Messaging
- Patient-Generated Health Data
- Clinical Information Reconciliation
- Immunization Registry Reporting
- Syndromic Surveillance Reporting
- Electronic Case Reporting
- Public Health Registry Reporting
- Clinical Data Registry Reporting
Transition: “2017 Advancing Care Information Transition Objectives and Measures”
- Security Risk Analysis*
- e-Prescribing*
- Provide Patient Access*
- Health Information Exchange*
- View, Download, or Transmit (VDT)
- Patient-Specific Education
- Secure Messaging
- Medication Reconciliation
- Immunization Registry Reporting
- Syndromic Surveillance Reporting
- Specialized Registry Reporting
To learn more about these measures, as well as ACI – and MIPS in general – visit qpp.cms.gov.