MIPS Advancing Care Information: Frequently Asked Questions

The Centers for Medicare and Medicaid Services (CMS) recently released the detailed specifications for the Advancing Care Information (ACI) performance category within the Merit Based Incentive Payment System (MIPS). In celebration, Able Health has compiled a list of the five most common questions we receive related to the ACI performance category.

1. Where are the detailed ACI measure specifications?

Here!

2. How is the Advancing Care Information Category scored?

The ACI performance category includes a set of base measures, all of which must be reported in order to earn any points in the category. Together, the base measures account for 50% of the performance category score, and reporting data for additional performance and bonus measures will account for the rest of the category score. The maximum score in the category is 100%, even though it is possible to report data that would earn more than 100%.

Clinicians and groups may select from two different sets of measures to report for the 2017 performance year, which are outlined below with associated scoring methodology:

  • Advancing Care Information Measures
  • Advancing Care Information Transition Measures
Advancing Care Information Measures
Advancing Care Information Measure Advancing Care Information Objective Required for Base Score (50%)? Contribution to Performance Score (up to 50%) Reporting Requirement
Security Risk Analysis Protect Patient Health Information Required 0 Yes/No statement
Electronic Prescribing e-Prescribing Required 0 Numerator/Denominator
Provide Patient Access Patient Electronic Access Required Up to 10% Numerator/Denominator
Patient-Specific Education Patient Electronic Access Not required Up to 10% Numerator/Denominator
View, Download, or Transmit (VDT) Coordination of Care Through Patient Engagement Not required Up to 10% Numerator/Denominator
Secure Messaging Coordination of Care Through Patient Engagement Not required Up to 10%  Numerator/Denominator
Patient-Generated Health Data  Coordination of Care Through Patient Engagement Not required Up to 10%  Numerator/Denominator
Send a Summary of Care Health Information Exchange Required  Up to 10%  Numerator/Denominator
Request/Accept Summary of Care  Health Information Exchange Required  Up to 10%  Numerator/Denominator
Clinical Information Reconciliation  Health Information Exchange Not required  Up to 10% Numerator/Denominator
Immunization Registry Reporting Public Health and Clinical Data Registry Reporting Not required  0 or 10% Yes/No statement

In addition to to the Advancing Care Information Measures above, the following measures can be reported for a bonus of up to 15%, which can contribute to the total category score of up to 100% as longs at the base measures are met:

Measure Category Bonus Reporting Requirement
Report to 1 or more of the
following public health and clinical
data registries:

  • Syndromic Surveillance Reporting
  • Electronic Case Reporting
  • Public Health Registry Reporting
  • Clinical Data Registry Reporting
5% bonus Yes/No statement
Report certain improvement activities using CEHRT 10% bonus Yes/No statement
Advancing Care Information Transition Measures
Advancing Care Information Measure Advancing Care Information Objective Required for Base Score (50%)? Contribution to Performance Score (up to 50%) Reporting Requirement
Security Risk Analysis Protect Patient Health Information Required 0 Yes/No statement
Electronic Prescribing e-Prescribing Required 0 Numerator/Denominator
Provide Patient Access Patient Electronic Access Required Up to 20% Numerator/Denominator
Health Information Exchange Health Information Exchange Required Up to 20%  Numerator/Denominator
View, Download, or Transmit (VDT)  Coordination of Care Through Patient Engagement  Not required  Up to 10% Numerator/Denominator
Patient-Specific Education Patient Electronic Access Not required Up to 10% Numerator/Denominator
Secure Messaging Coordination of Care Through Patient Engagement Not required Up to 10%  Numerator/Denominator
Medication Reconciliation Medication Reconciliation Not required Up to 10%  Numerator/Denominator
Immunization Registry Reporting Public Health and Clinical Data Registry Reporting Not required  0 or 10% Yes/No statement

In addition to the Advancing Care Information Transition Measures above, the following measures can be reported for a bonus of up to 15%, which can contribute to the total category score of up to 100% as longs at the base measures are met:

Measure Category Bonus Reporting Requirement
Report to 1 or more of the
following public health and clinical
data registries:

  • Syndromic Surveillance Reporting
  • Specialized Registry Reporting
5% bonus Yes/No statement
Report certain improvement activities using CEHRT 10% bonus Yes/No statement

3. Are there still hardship exemptions like there were under Meaningful Use?

Yes, CMS has finalized the policy to re-weight the advancing care information performance category to zero percent of the MIPS final score for MIPS eligible clinicians facing a significant hardships. Like under the Meaningful Use program, CMS continues to assume that the clinicians facing the hardships listed below may not have sufficient measures applicable and available to them for the Advancing Care Information performance category. Categories of significant hardship include:

  • Insufficient Internet Connectivity
  • Extreme and Uncontrollable Circumstances
  • Lack of Control over the Availability of CEHRT
  • Lack of Face-to-Face Patient Interaction

If a MIPS eligible clinician is exempt from reporting for the ACI category based on significant hardship, the ACI score will be set to zero, and the 25 points will be moved to the Quality performance category.

If a MIPS eligible clinician applies for their Advancing Care Information performance category to be reweighted under this policy but subsequently determines that their situation has changed and they believe there are sufficient ACI measures applicable and available to them, they may report on the measures. If they choose to report, they will be scored on the Advancing Care Information performance category like any other MIPS eligible clinician.

4. Will there be the same reporting system for ACI as there was for Meaningful Use?

No, there will be a new reporting system for ACI. CMS has finalized the policy that ACI measures will be able to be reported via EHR, Registry, QCDR, and attestation. The ability to report ACI measures via Registry and QCDR is new under MIPS, and CMS has stated that they are encouraging consolidation of reporting for all categories through a single submission mechanism.

Keep your eye on qpp.cms.gov throughout the year for new resources related to ACI measure reporting.

5. For group reporting, does the ACI data have to be reported for the whole group, or can it be reported at the provider level?

For group reporting, the ACI data must be aggregated for the group, with one numerator and denominator or yes/no answer for the whole group for each measure. If the group is using multiple EHR technologies, the numbers must be aggregated across the technologies before the data is reported. Here is some additional detail on reporting ACI base measures and performance measures as a group:

  • Base measures: For the base measures in the ACI category, groups only need one provider to report successfully to achieve a “yes” or a numerator of 1 for each measure to get credit. This means that as long as one provider in the group completes all the base measures, then they whole group will get credit for the base measures (50% of the category score).
  • Performance measures: For the performance measures, groups will need to sum the numerator and denominator across all providers using a Certified EHR Technology (CEHRT), and that will be used as the numerator and denominator for the group. It is not acceptable to submit a numerator and denominator for just one eligible clinician in the group for the performance measures, unless only one eligible clinician is using CEHRT.

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Further reading:
Quick-Look Comparison: MIPS 2017 vs. 2018 requirements
Need to Know: Highlights from the 2018 QPP Proposed Rule and What It Means for You

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