Welcome back to Qvera’s series on MACRA and Interoperability. We have already reviewed the MACRA legislation that established the new Medicare Quality Payment Program (QPP). Following our review, we provided a broad overview of the MIPS participation pathway and the four categories that contribute to the composite MIPS score. Today we are going to take a closer look at one of those categories: Advancing Care Information (ACI).
Advancing Care Information (ACI) replaces Meaningful Use (MU)
The American Recovery and Reinvestment Act of 2009 established incentive payments for eligible professionals (EP’s), eligible hospitals, critical access hospitals, and Medicare Advantage organizations to adopt and implement electronic health records. In 2011, the Medicare and Medicaid Electronic Health Record (EHR) Incentive Program, also known as “Meaningful Use (MU),” was established to encourage the adoption and use of certified electronic health records with advancing stages of meaningful use requirements moving users from the capture of clinical data to proving quality improvement through the use of health IT.
In November of 2016, the MIPS criteria were published as part of the new Quality Payment Program (QPP) and established the Advancing Care Information (ACI) category as a replacement for the MU program for EP’s participating through Medicare. 2017 is the first performance year for ACI under MIPS and during this transition year providers may “pick-their-pace” for participation.
The final rule for participation year 2 of the QPP was published Nov 2, 2017, and aims to reflect clinician feedback about the importance of incorporating clinical workflows into the legislation. In the introduction to the final rule, CMS officials write:
“Clinicians have told us that they do not separate their patient care into domains and that the Quality Payment Program needs to reflect typical clinical workflows in order to achieve its goal of better patient care.”
Clinicians are relieved by the announcement that 2014 CEHRT can be used for the second year of the program, relieving the impending deadline of having 2015 CEHRT installed before January 1 of 2018. An initial review of key points was written by the editors of Healthcare Informatics. A closer look at the changes found in the final rule will be forthcoming on our blog.
Interoperability & Advancing Care Information (ACI)
The ACI Category makes up 25% of the MIPS score (for both 2017 and 2018) and allows 2017 participants to report on only 5 required measures for full participation (to earn the maximum incentive payment).
The 5 required measures are:
- Security Risk Analysis
- Provide Patient Access (Portal)
- Send Summary of Care
- Request/Accept Summary of Care
Participants can choose to report on additional measures (up to 9) for more points, including bonus credit for reporting to Public Health and Clinical Data Registries. Health Data Exchange is a key component in nearly every measure – including familiar workflows like participation in state immunization registries, the exchange of Transition of Care CDA’s, and secure messaging between patients and providers. Many of the new ACI measures, however, involve emerging workflows that increase the accessibility and portability of health information to both patients and their healthcare team. These workflows demonstrate a shift from just “checking the box” for MU compliance to a focus on a truly meaningful exchange that improves the quality of care. Some of these workflows include:
- Integration of patient health data from personal devices
- Expanded reconciliation of clinical data
- Strategic submissions to public health and specialized registries
The trend across all categories of the new Quality Payment Program is to focus on workflows that can impact patient outcomes. The increased complexity of these workflows requires interoperability and interfacing solutions with the flexibility to adapt to patient-centered workflows that involve data from a number of disparate sources and data formats. Initial review of the final rule for year 2 participation indicates that this focus is unwavering and the complexity of ACI measures is expected to increase. Stay tuned for a more detailed review of the Year 2 Final Rule.