Loyola University Chicago School of Law, JD 2017
This article will spell out the details for the Advancing Care Information (ACI) category of the Merit Based Incentive Payment System (MIPS). This category accounts for 25% of a clinician’s overall composite score and is intended to replace the current Meaningful Use program. The ACI category looks at areas such as security of protected health information (PHI), patient electronic access, health information exchange to permit interoperability, and more.
Clinicians will now be able to report customizable measures that reflect how their practice uses electronic health records (EHR) technology with a special emphasis on interoperability and information exchange. Clinicians are given flexibility to choose which measures they want to report in order to give themselves the best chance at achieving an optimal score. However, it is important to note that clinicians who are hospital-based will not be scored on ACI. This category will be weighted at 0% of the overall composite score for those clinicians since they have little control over how the hospital utilizes EHR. This means that the other 3 categories are that much more important for hospital-based clinicians, with special emphasis on the Quality and Clinical Practice Improvement Activities for performance year 2017 since Resource Use will not be factored into the composite score.
A clinician may score up to 100 percentage points out of a possible 131 percentage points. If a clinician reaches 100 points, they will get the full 25 points towards their composite score. ACI scoring is broken up into two categories with the possibility of receiving 1 additional bonus point: a Base Category worth 50 percentage points and a Performance Category worth 80 percentage points. In order to begin accumulating points under the performance category, a clinician must first meet the base category score of 50 points.
To receive the base category score, a clinician need only report either a yes/no or numerator/denominator answer for 5 specified measures (this number has decreased from the suggested 6 categories in the proposed rule). The 5 measures required for the base score are electronic prescribing, patient electronic access, security risk analysis, summary of care record, and summary of care measure. If a clinician does not report on all 5 of the base score categories, they will receive a 0 for the ACI category and will not be permitted to achieve points under the performance category.
The performance category then accounts for up to 80 percentage points, and clinicians are able to select the measures they believe will help them achieve the highest possible score. These additional measures are optional. However, a clinician will only receive 50 percentage points if he or she chooses not to report additional measures thereby lowering a physician’s overall composite score. Prior to the performance year, CMS proposes to set benchmarks for each measure which will be used to determine a clinician’s performance in that category. CMS has proposed 3 objectives: patient electronic access, coordination of care through patient exchange, and health information exchange. There are 8 measures to report under these 3 objectives, each measure worth up to 10 points.
The remaining bonus point will be rewarded to those clinicians who report additional data to optional registries, such as the Intelligent Research in Sight (IRIS) registry which collects data via EHRs to compile patient data relating to eye diseases and conditions. As an added bonus to the final rule, CMS included an additional bonus point for the transition year (performance year 2017) for improvement activities that utilize CEHRT.
CMS has employed the Advancing Care Information as a catalyst to promote interoperability amongst health care information. CMS hopes that this category will spur the development of technology that is customizable to meet the needs of the way patients and physicians interact. Providers should look to the EHR technology they currently use and how they can optimize certain features to score favorably under ACI measures. Utilizing tools already available to an organization will be the most efficient and least expensive method for optimizing this score. Providers may also want to look at options for bringing in new technological resources to help bolster their ACI score. For example, a patient messaging service can be a relatively inexpensive tool to add to your practice that will not only help your ACI score, but will likely also score well with your patients. Understanding where a practice can gain points under the ACI category is the first step in developing a plan of action for responding to the changing reimbursement scheme. Compliance officers should aim to ensure that their practice will meet all required elements of the base score and then help to adapt the practice to make the most of the optional performance score points. Compliance officers should be involved in every step of this process. As new technologies are brought into the practice, data privacy and security concerns should be a high priority. Advancing the technology used within the practice will help maximize the ACI score, however, the privacy of patients should always take precedent. ACI is currently set to remain at 25% of a clinician’s overall composite score, indicating that advancements in this category are a priority for CMS and should be for clinicians as well.