- As part of the Merit-based Incentive Payment System (MIPS), the advancing care information performance category will replace meaningful use for eligible clinicians — and place a strong emphasis on healthcare interoperability and health data exchange.
As a refresher, the proposed rule for MACRA implementation establishes the Quality Payment Program, which includes two incentive pathways for eligible clinicians — MIPS and Alternative Payment Models (APMs). Combining the EHR Incentive Programs, the Physician Quality Reporting System, and the Value Modifier Program, MIPS comprises four performance categories: resource use, quality, advancing care information, and clinical practice improvement activities.
During the first performance year of MIPS (whenever that may be), advancing care information will constitute 25 percent of an eligible clinician's performance score used to determine a positive, negative, or neutral payment adjustment. (The performance category's composite score is the sum of base score, performance score, and bonus point — more on that at another time.)
Returning to the substance of this performance category, four of the six objectives proposed by the Centers for Medicare & Medicaid Services (CMS) put health data exchange front and center of a MIPS eligible clinician's use of certified EHR technology.
First is the patient electronic access category. According to the proposed rule, MIPS participants must provide at least one patient with "timely electronic access to their health information and patient-specific education" in two ways:
(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.
In addition to this patient access measure, MIPS eligible clinicians are also responsible for using "clinically relevant information" in their CEHRT to provide at least one patient with specific to identify "patient-specific educational resources" and "electronic access to those materials." Doing so would satisfy the patient-specific education measure as part of the patient electronic access objective.
Second is the objective for coordination of care through patient engagement. Three measures comprise this objective related to health data exchange.
To begin with, MIPS eligible clinicians must ensure that at least one patient "actively engages with the EHR in one of three ways:
(1) view, download or transmit to a third party their health information; or (2) access their health information through the use of an API that can be used by applications chosen by the patient and configured to the API in the MIPS eligible clinician's certified EHR technology; or (3) a combination of (1) and (2).
Seemingly redundant with the patient electronic access measure, the emphasis here is on using CEHRT to facilitate health data exchange rather than on the timeliness of the action.
Next, MIPS eligible clinicians are required to use CEHRT to send a secure message to at least one patient in form of an original message or a response to patient message. And then finally, MIPS participants must incorporate patient-generated health data "or data from a non-clinical setting" directly into their CEHRT for at least one patient. The proposed rule does not specify how this is to take place.
The objective most directly associated with health data exchange is one call "health information exchange." Here the focus is on the electronic exchange of patients records between providers.
First there is the measure for sending:
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.
The second focuses on receiving:
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.
Clinical information reconciliation is the third and final measure for this objective:
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 performs clinical information reconciliation. The clinician must implement clinical information reconciliation for the following three clinical information sets: (1) Medication. Review of the patient's medication, including the name, dosage, frequency, and route of each medication. (2) Medication allergy. Review of the patient's known medication allergies. (3) Current Problem list. Review of the patient's current and active diagnoses.
The public health and clinical data registry reporting objective rounds out the advancing care information requirements centering on health data exchange. Of the five measures proposed, four are optional. As for what is required, MIPS eligible clinicians must demonstrate "active engagement with a public health agency to submit immunization data and receive immunization forecasts and histories from the public health immunization registry/immunization information system (IIS)."
The remaining optional measures deal with "active engagement" relative to syndromic surveillance reporting, electronic case reporting, public health registry reporting, and clinical data registry reporting. MIPS eligible clinicians who report on more than one public health registry can qualify for a bonus point that will positively impact their composite score for the advancing care information performance category.