For the 2017 reporting year, AQI is not collecting or submitting Advancing Care Information (ACI) data to CMS. MIPS-eligible clinicians (ECs) who are not sure whether they qualify for an exemption from the Advancing Care Information performance category or those who are considering participating in ACI should review the following steps for deciding the best path for possible ACI attestation and data submission.
Note: If practices are submitting quality and improvement activity MIPS component data as a group to AQI AND they are required to or elect to submit ACI data, they must then submit that ACI data as a group via a separate reporting mechanism or vendor.
STEP 1: Check your MIPS Participation Status on the Quality Payment Program (QPP) website.
Enter your 10-digit National Provider Identifier (NPI) number in the QPP site to determine whether you are exempt from MIPS with the first review. Please note, based upon a second determination period that runs through August 31, 2017, ECs have an updated exemption status.
STEP 2: Check your Certified Electronic Health Record Technology (CEHRT) to determine which edition you have and plan to attest accordingly.
First, make plans to acquire, verify or update Certified Electronic Health Record Technology (CEHRT) to the correct edition. For the 2017 performance period, MIPS eligible clinicians can use EHR technology certified to the 2014 Edition, a combination of both 2014 and 2015 Editions or the 2015 Edition. In 2018 and beyond, eligible clinicians must use the 2015 Edition to receive credit for ACI.
Please note, CMS may allow flexibility in the 2018 performance year and may allow ECs to use the 2014 Edition, pending rulemaking.
If a MIPS eligible clinician switches from 2014 Edition to 2015 Edition CEHRT during the performance period, the data collected for the base and performance score measures should be combined from both the 2014 and 2015 Edition of CEHRT.
ECs using 2014 CEHRT should review the 2017 Advancing Care Information Transition Objectives and Measures as these measures are slightly different from objectives and measures for CEHRT 2015.
The Office of the National Coordinator for Health Information Technology (ONC) has developed a comprehensive database of certified EHR technology where ECs can check their CEHRT.
STEP 3: Determine whether you are a hospital-based MIPS eligible clinician.
In the 2016 MACRA final rule (outlining the 2017 program requirements), CMS defined a hospital-based clinician as a MIPS-eligible clinician who furnishes 75% or more of their covered professional services in POS 21 (inpatient hospital), POS 22 (on campus outpatient hospital), or POS 23 (emergency room).
CMS will notify clinicians of their status in the next few months. Hospital-based MIPS ECs will have their ACI category automatically reweighted to zero and those points shifted to the Quality component. Please note, those hospital-based ECs that wish to participate despite having the exemption may submit ACI data and will receive an ACI score even if they were not required to submit data.
STEP 4: Determine whether you are a non-patient-facing MIPS-eligible clinician.
In the 2016 MACRA final rule (outlining the 2017 program requirements), CMS defined non-patient-facing clinicians as a MIPS-eligible clinician who performs fewer than 100 procedures with patient facing codes annually. CMS defined non-patient-facing groups as those with greater than 75 percent of individual ECs in a group meeting the individual criteria for non-patient-facing status.
CMS will notify clinicians of their status in the next few months. Non-patient-facing MIPS ECs will have their ACI category automatically reweighted to zero and those points shifted to the Quality component. Please note, those non-patient-facing ECs that wish to participate despite having the exemption may submit ACI data and will receive an ACI score if they were not required to submit data.
STEP 5: Determine whether you qualify for additional exemptions and apply using the CMS Hardship Application.
There are three additional exemptions from ACI that require submission of a CMS Hardship Application:
- Insufficient Internet Connection: CMS has defined as practicing in an area without sufficient Internet access or facing insurmountable barriers to obtaining infrastructure (lack of broadband, etc.)
- Extreme and Uncontrollable Circumstance: CMS has defined as natural disasters, practice or hospital closure, severe financial distress, EHR certification/vendor issues
- Lack of Control over the Availability of CEHRT: CMS has defined as the inability to control CEHRT availability in more than 50 percent of patient encounters
The CMS Hardship Application for the 2017 Reporting Year will be released at a later date. If CMS grants one of these hardships, ECs will have their ACI category automatically reweighted to zero and those points shifted to the Quality component.
Those ECs who have an exemption from ACI in 2017 and do not wish to participate need not review Steps 6-9.
STEP 6: If you are participating in ACI, pick a performance period of at least 90 days.
For 2017, CMS has outlined several participation options in its “Pick Your Pace” program. In order to earn a small or moderate positive payment adjustment, those ECs participating in ACI should attest to and submit at least 90 days of 2017 data to CMS.
STEP 7: Review the 2017 Scoring Requirements and determine which score components are most applicable to you and your practice.
The ACI Score is composed of a Base Score (50 percent), a performance score (up to 90%) and bonus scores (up to 15 percent). Although ECs may score over 100 percent, the score is capped at 100 percent.
ECs must report all the base score measures successfully in order to receive any point in the ACI component. For more information on scoring, visit ASA Advancing Care Information Scoring.
To maximize their ACI scores, ECs should review the performance measures and bonus point opportunities and attest and submit data to those that are most applicable.
STEP 8: Choose your submission method and verify its capabilities.
ECs who are reporting as individuals can attest via:
- Attestation to CMS using the QPP website. CMS will release additional guidance at its new portal at a later date but has provided a sample CSV-file.
- Qualified Clinical Data Registry (QCDR) – CMS has compiled a list of 2017 CMS Approved QCDRs along with the performance categories supported by the QCDRs.
- Qualified Registry (QR) - CMS has compiled a list of 2017 CMS Approved QRs along with the performance categories supported by the QRs.
- Electronic Health Record (EHR). ECs should work with their EHR vendors to begin to collect the required data for submission.
Groups have the four options listed above for attestation. In addition, groups that have registered for the 2017 CMS Web Interface prior to June 30, 2017, can attest to Advancing Care via the CMS Web Interface.
For more information on Group Reporting versus Individual Reporting, QCDR and QR Reporting Requirements and other relevant considerations, please see the ASA Quality Reporting – NACOR Page.
STEP 9: Submit your ACI data by March 31, 2018.