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CMS Guidance for MIPS Advancing Care Information Measures

CMS officials recently detailed expectations for providers working to use certified EHR technology in satisfying MIPS advancing care information measures in 2017.

MIPS requirements

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By Kate Monica

- With the Merit-based Incentive Payment System taking effect this year, eligible clinicians are eager to receive clarification regarding the ability of their EHR technology to support them in satisfying requirements of this Quality Payment Program pathway.

At HIMSS17, CMS representatives set out to answer questions about MIPS reporting expectations during the current transition year, such as the certified EHR technology necessary for completing the task.

As reported by RevCycleIntelligence.com, MIPS Policy Developer Leader Molly MacHarris explained how providers can determine which Advancing Care Information measures to use when submitting data for the category based on the certified EHR technology they are using.

“When we went out with our proposed rule last year we received a number of comments from across the industry and from all clinicians saying that we were moving a little too fast,” she stated. “So, we wanted to take a step back and ensure that anyone who wants to participate in the program can participate.”

MIPS consists of four performance categories: quality, cost, advancing care information, and improvement activities.

The quality category accounts for the most substantial portion of provider performance (60%), followed by advancing care information (25%), improvement activities (15%), and cost (0% in 2017, but to be a factor in subsequent years).

A provider’s total MIPS score will be used to decide the positive, neutral, or negative Medicare payments he will receive in 2019.

The advancing care information component of the MIPS performance score focuses on eligible clinician CEHRT use to coordinate patient care and promote EHR interoperability.

Under MIPS, eligible clinicians have the option to submit their advancing care information data either individually or as part of a group. Furthermore, participation in the advancing care information category is not compulsory for eligible clinicians, nurse practitioners, physician assistants, clinical nurse specialists, and certified registered nurse anesthetists.

If any eligible clinicians are excluded from the advancing care information category or are experiencing hardships in accordance with the 21st Century Cures Act, they are permitted to shift the 25-percent performance weight from this category to the quality performance category.

In replacing the requirements of the Medicare EHR Incentive Program, advancing care information requires eligible clinicians to fulfill the base score measure requirements for security risk analysis, e-prescribing, patient access, sending a summary of Care, and requesting/accepting the same for a minimum of 90 days, according to the Quality Payment Program measures fact sheet.

For bonus credit, eligible clinicians can report public health and clinical data registry reporting measures and use certified EHR technology to fulfill specific improvement activities in that performance category, which is new this year.

While presently all providers are expected to use 2015 CERHT in 2018 for MIPS reporting, 2014 CERHT is acceptable for reporting in 2017.

Providers using the 2014 edition CERHT will use the 2017 advancing care information transition objectives and measures based on Stage 2 Meaningful Use. Meanwhile, providers using the 2015 edition CERHT are encouraged to choose the advancing care information objective and measures, said Senior Technical Advisor in the Division of Health Information Technology Elizabeth Holland.

Eligible clinicians participating in the program in 2017 are encouraged to submit data for advanced activities including medication reconciliation, secure messaging, and patient-generated health data for additional achievement in performance score measure points.

“If you submit higher numerators and denominators that equate to higher percentages, you have the potential to earn more points,” Holland added.

Ultimately, CMS will determine a provider’s total score in this category by combining scores for base measure, performance measure, and bonus points.

With these stipulations clearly outlined, CMS intends to avoid the confusion among providers that affected meaningful use requirements in years past. Considering the amount of providers subject to payment penalties under the former program, providers are ready for less stringent policies focused more on encouraging participation than punishing regulatory missteps. 

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