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Health Data Exchange, Interoperability Requirements of MIPS

Health data exchange is the goal of the advancing care information performance category under MIPS.

By Kyle Murphy, PhD

- One guiding principle behind the advancing care information performance category under the Merit-based Incentive Payment System is to bridge information gaps between care settings.

Health data exchange in advancing care information

To that end, the final rule for the Quality Payment Program — of which MIPS is one path; the other being Advanced Payment Models (APMs) — requires eligible clinicians to report five measures within this category that are focused on health IT interoperability in order to at the very least avoid a negative payment adjustment for participation in the first year of the program.

As the Centers for Medicare & Medicaid Services noted in the announcement of the final rule, 2017 is a transition year. In subsequent years these requirements and their thresholds will increase.

"Measures and objectives in the advancing care information performance category focus on the secure exchange of health information and the use of certified electronic health record technology (CEHRT) to support patient engagement and improved healthcare quality," the federal agency

The requirement for reporting five measures is down from the 11 put forth in the proposed rule and the 18 previously set for eligible professionals in Stage 3 Meaningful Use, which MIPS and the advancing care information performance category replace. All told, the advancing care information performance category comprises 25 percent of an eligible clinician's 2017 MIPS performance.

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"All other measures would be optional for reporting. Reporting on all five of the required measures would earn the MIPS eligible clinician 50 percent," CMS explained. "Reporting on the optional measures would allow a clinician to earn a higher score. For the transition year, we will award a bonus score for improvement activities that utilize CEHRT and for reporting to public health or clinical data registries."

The requires measures to be reported on for a minimum of 90 days are:

  • security risk analysis
  • e-prescribing
  • provide patient access
  • send summary of care
  • request/accept summary of care

Reporting on up to 9 measures for no less than 90 days will qualify eligible clinicians for additional credit in performance year 2017.

Here's a closer look at the five required advancing care information measures.

Security risk analysis (1) & e-prescribing (2)

Neither the security risk analysis nor e-prescribing objectives and measures carry a performance score weight as compared to the others which each carry up to 10 percent.

For the former, each eligible clinician is required to perform a security risk analysis, which includes "addressing the security (to include encryption) of ePHI data created or maintained by certified EHR technology," and "implement security updates as necessary and correct identified security deficiencies as part of the MIPS eligible clinician's risk management process."

For the electronic prescribing objective, the measure requires participants to query a drug formulary for and transmit electronically using CEHRT for no less than "one permissible prescription."

Provide patient access (3)

Here is where things start to get interested for health data exchange under MIPS and the advancing care information performance category:

For at least one unique patient seen by the MIPS eligible clinician: (1) The patient (or the patient authorized representative) is provided timely access to view online, download, and transmit his or her health information; and (2) The MIPS eligible clinician ensures the patient's health information is available for the patient (or patient-authorized representative) to access using any application of their choice that is configured to meet the technical specifications of the Application Programing Interface (API) in the MIPS eligible clinician's certified EHR technology.

Considering the challenge of patient engagement as part of Stage 2 Meaningful Use, this category is still likely to cause concern for some participants despite its requirement for one patient.

Send summary of care record (4), summary of care measure (5)

These two requirements involve the same document, the difference being whether the eligible clinician is sending or receiving information.

Here's the measure for the sender:

For at least one transition of care or referral, the MIPS eligible clinician that transitions or refers their patient to another setting of care or health care provider-(1) creates a summary of care record using certified EHR technology; and (2) electronically exchanges the summary of care record.

Compare that with the measure for the receiver:

For at least one transition of care or referral received or patient encounter in which the MIPS eligible clinician has never before encountered the patient, the MIPS eligible clinician receives or retrieves and incorporates into the patient's record an electronic summary of care document.

For the record, only these two required measures fall under the objective category of health information exchange. The others belong to separate categories — protect patient health information e-prescribing, and patient electronic access, respectively.

That 40 percent of the advancing care information measures focus especially on health information exchange begs the question of whether the performance category lives up to its purpose in the first year of MIPS to support interoperability and the efficient sharing of health data.

View the complete this of 15 advancing care information measures here.

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