Physician practices have found plenty to be unhappy about in the CMS' Quality Payment Program. The overall complexity of the Merit-Based Incentive Payments System (MIPS) is staggering, because it requires practices to determine which quality and improvement activities to focus on. But the technology-related segment of MIPS, Advancing Care Information (ACI), which makes up 25 percent of the overall score, has been a smoother transition, because there has been a logical progression from Meaningful Use (MU), consultants and providers say.
“If you have been successful in MU, ACI should not really be a challenge for you,” says Dan Golder, MD, a principal with Chicago-based healthcare IT consulting firm, Impact Advisors LLC. “MIPS as a whole is another whole story,” Golder stresses, “but I think ACI correlates fairly well to MU.”
Not Many Differences
Other consultants agreed that if a provider reported MU for the 2016 reporting year, they should have little problem with the ACI portion of MIPS in 2018. With the reporting period remaining at 90 days for 2018, a provider can use either a 2014- or 2015-certified EHR. If using a 2014 certified EHR, the provider will report on what CMS calls the “transition measures,” which are a subset of the modified Stage 2 measures reported by everyone for 2016. If your EHR system is 2015-certified, you can choose to report either the 2017 ACI transition measures set or the ACI measures set. Using the 2015- certified EHR gets providers extra credit.
Among the ACI base measures, providers should already have experience doing a security risk analysis for MU. Most are already e-prescribing and offering patients electronic access to their records through a portal. “Sending summaries of care has always been a bit tricky in MU, but people should have that down by now,” Golder says.
The main difference between MU and ACI is in the scoring, explains Jeanne Chamberlin, a practice management consultant with MSOC Health in Charlotte, N.C. “Under MU, you had to meet the threshold or an exception for each measure — the whole program was all or nothing. ACI is much easier,” she says. Using the transition measures, a provider is required to report four measures with a “yes” attestation or threshold of one patient to receive the base score of 50 points (out of 100). Additional points are based on how high your performance score is on these and other measures. You can choose not to enter data for a specific measure and still receive the highest possible score of 100 points.
One challenge is that the overall complexity of MIPS finds many smaller practices reliant on their EHR vendors to prepare for the requirements and reporting, and many of those vendors are struggling to keep up, Chamberlin says. She says CMS delaying the requirement to have a 2015-certified version and some Stage 3 MU measures until 2019 is extremely helpful.
"But I expect many EHR vendors will not be ready for that new deadline of 90 days in Calendar Year 2019 either,” she says. There are differences between the larger EHR vendors and smaller ones in terms of being able to adjust to the fluidity of the rules in time to help providers, Golder says.