Advancing Care Information (ACI)

MIPS Payment Track:

Advancing Care Information (ACI) Performance Category

MIPS: Explaining the Advancing Care Information (ACI) Performance Category

The Medicare Access and CHIP Reauthorization Act (MACRA) was passed and signed into law in April 2015. Under MACRA, eligible clinicians (ECs) will participate in either the Merit-based Incentive Payment System (MIPS) or an Advanced Alternative Payment Model (AAPM). MIPS and AAPMs are collectively referred to as the Quality Payment Program (QPP).

With the MIPS track, ECs receive a final score based on performance in four performance categories: quality, cost, advancing care information (ACI), and improvement activities.

To give ECs more time to learn about and adjust to QPP, the Centers for Medicare & Medicaid Services (CMS) deemed 2017 a transition year to “Pick Your Pace.”

Advancing Care Information (ACI) Reporting

The ACI category replaces the Medicare EHR Incentive Program (Meaningful Use). The measures within the category are based on the measures from Meaningful Use.

Eligible clinicians must report on a set of five required measures, referred to as base measures. For the 2017 transition year, ECs can report on a set of four base measures. Failure to report any one of the base measures will result in a score of zero for the entire ACI performance category. ECs can increase their score by reporting on additional measures (see ‘Advancing Care Information Scoring’ below).

Eligible clinicians can report using a qualified registry, qualified clinical data registry (QCDR), electronic health record (EHR), CMS Web Interface, or through attestation.

  • Clinicians can only use one reporting method per performance category (i.e., you cannot report ACI using an EHR and via attestation).
  • If choosing to report as a group, all performance categories must be reported as a group and will be scored as a group.

Beginning in 2018, ECs are required to use 2015 edition certified electronic health record technology (CEHRT). The 2014 edition, 2015 edition, or a combination of the 2014 edition and 2015 edition can be used in 2017.

Eligible clinicians without an EHR are eligible to participate in MIPS, but they will not be eligible for any of the points in the ACI category.

Reminder:

While ACI and other MIPS categories are referred to as ‘performance categories,’ the term ‘performance score’ specifically refers to one of two scores in the ACI category.

ACI Scoring

The ACI category score is broken into two parts: the base score and the performance score. The base score assesses if a clinician performed the measure (activity) and the performance score assesses how well a clinician performed the measure.

The base score is achieved by reporting the required base measures. Clinicians will receive 50 points for attesting to the base measures.

Note: Failure to report any of the required base measures will result in a base score of zero and an ACI performance category score of zero.

The performance score assesses a clinician’s performance on an individual measure and assigns up to 10 points per measure based on the performance rate (numerator/denominator).

  • Three of the required base measures can be included in the performance score.
  • Clinicians can report on additional measures to increase the performance score.
  • The performance score allows a clinician to earn up to an additional 90 percentage points toward their ACI category score.
  • While there is potential to earn a score higher than 100, the ACI category score is capped at 100.

There are no thresholds within the ACI category, meaning a clinician does not need to report a certain number or percent of patients in order to receive points in the category. Clinicians are scored based on their individual performance. The following table indicates if the measure is included in the base score, performance score, or both.

Measure

Base Score (required)

Performance Score

Measure

:

Security Risk Analysis

Base Score (required)

:

Yes

Performance Score

:

No

Measure

:

e-Prescribing

Base Score (required)

:

Yes

Performance Score

:

No

Measure

:

Provide Patient Access

Base Score (required)

:

Yes

Performance Score

:

Yes

Measure

:

Patient-Specific Education

Base Score (required)

:

No

Performance Score

:

Yes

Measure

:

View, Download, Transmit

Base Score (required)

:

No

Performance Score

:

Yes

Measure

:

Secure Messaging

Base Score (required)

:

No

Performance Score

:

Yes

Measure

:

Patient-Generated Health Data*

Base Score (required)

:

No

Performance Score

:

Yes

Measure

:

Send a Summary of Care

Base Score (required)

:

Yes

Performance Score

:

Yes

Measure

:

Request/Accept Summary of Care*

Base Score (required)

:

Yes

Performance Score

:

Yes

Measure

:

Clinical Information Reconciliation

Base Score (required)

:

No

Performance Score

:

Yes

Measure

:

Immunization Registry Reporting

Base Score (required)

:

No

Performance Score

:

Yes

*Measure not required in 2017

Points are assigned based on performance according to the following scale:

Performance Rate

Performance Percentage Points Earned

Performance Rate

:

1-10%

Performance Percentage Points Earned

:

1%

Performance Rate

:

11-20%

Performance Percentage Points Earned

:

2%

Performance Rate

:

21-30%

Performance Percentage Points Earned

:

3%

Performance Rate

:

31-40%

Performance Percentage Points Earned

:

4%

Performance Rate

:

41-50%

Performance Percentage Points Earned

:

5%

Performance Rate

:

51-60%

Performance Percentage Points Earned

:

6%

Performance Rate

:

61-70%

Performance Percentage Points Earned

:

7%

Performance Rate

:

71-80%

Performance Percentage Points Earned

:

8%

Performance Rate

:

81-90%

Performance Percentage Points Earned

:

9%

Performance Rate

:

91-100%

Performance Percentage Points Earned

:

10%

Clinicians can earn 5 bonus percentage points by attesting to active engagement with other Public Health or Clinical Data registries (excluding Immunization Registry). Active engagement means completing registration to submit data to a registry, testing and validating the electronic submission of data, or actively electronically submitting data to a registry.

Clinicians can earn 10 bonus percentage points by reporting at least one of 18 improvement activities using CEHRT. See Appendix B (on page 9) in this CMS document(qpp.cms.gov) for a list of improvement activities.

To calculate the ACI category score, total points from the base score, performance score, and any bonus points. Take those combined scores (out of a maximum 100), and multiply it by 0.25 to get the ACI performance category score. The ACI score is weighted at 25%.

Attestation Information

In addition to reporting on measures, clinician’s must also attest to several statements to receive points in the ACI category. These attestations are related to provisions that:

  • Allow the Office of the National Coordinator (ONC) to review the performance of health information technology (HIT), referred to as “direct review,” and
  • Ensure clinicians do not engage in activities that would knowingly or willfully prevent or obstruct the electronic exchange of information (known as “information blocking”) within their certified electronic health record technology (CEHRT).

Clinicians will follow the instructions of their selected reporting method to attest.

Direct Review

Clinicians must attest they are aware of the requirement to cooperate in good faith with ONC direct review of their HIT if a request is received. If a request has been received, clinicians must also attest that they did cooperate in ONC direct review.

Direct review of HIT allows the ONC to evaluate the performance of certified HIT in certain circumstances, including in response to problems and complaints with the performance of CEHRT.

To cooperate in good faith means the clinician responds in a timely manner to requests for information and accommodating requests by ONC to access the clinician’s CEHRT. It is expected that ONC will work to accommodate a clinician’s schedule and other circumstances when requesting information. ONC predicts that a very small percentage of ECs will be asked to participate in direct review.

Information Blocking

Clinicians must attest to three statements declaring they did not knowingly or willfully limit the electronic exchange of information.

The first statement attests that the clinician did not take actions to limit or restrict the compatibility or interoperability of CEHRT. This includes actions such as purposefully disabling certain functionalities within the CEHRT.

The second statement is related to the implementation of CEHRT and attests that the clinician implemented technology, standards, and workflows that ensured the CEHRT was connected according to applicable law, compliant with information exchange standards, allowed patients timely access to electronic health information, and allowed the timely bi-directional exchange of information with other health care providers.

The third statement is related to how the clinician used CEHRT during the reporting period and attests that the clinician responded in a timely manner to requests to retrieve or exchange electronic health information with patients and other health care providers, regardless of the requestor’s affiliation.

Hardship Exceptions

Eligible clinicians who have faced significant hardships can apply for an exception. The exception will reassign the ACI category weight (25%) to the quality performance category.

To qualify for a significant hardship exception, an EC must have experienced one of the following during the reporting period:

  • Insufficient internet connectivity (based on the Federal Communication Commission’s National Broadband Map(www.broadbandmap.gov));
  • Extreme or uncontrollable circumstances (such as natural disaster or significant issues related to CEHRT);
  • Lack of control over the availability over CEHRT (control does not mean final decision-making authority or practicing as part of a group); and/or
  • Lack of face-to-face interaction (for ECs who are non-patient facing).

ACI Transition Measures in 2017

The following are available to ECs using 2014 edition CEHRT, 2015 edition CEHRT, or a combination of the two.

Objective

Measure

Measure Description

Objective

:

Protect Patient Health Information

Measure

:

Security Risk Analysis

Measure Description

:

Conduct or review a security risk analysis, including addressing the security (to include encryption) of electronic protected health information (ePHI) data created or maintained by CEHRT, and implement security updates as necessary and correct identified security deficiencies as part of the MIPS-eligible clinician’s risk management process.

Objective

:

Electronic Prescribing

Measure

:

e-Prescribing

Measure Description

:

At least one permissible prescription written by the MIPS-eligible clinician is queried for a drug formulary and transmitted electronically using CEHRT.

Objective

:

Patient Electronic Access

Measure

:

Provide Patient Access

Measure Description

:

At least one patient seen by the MIPS-eligible clinician during the performance period is provided timely access to view online, download, and transmit to a third party their health information subject to the MIPS-eligible clinician’s discretion to withhold certain information.

Objective

:

View, Download, or Transmit (VDT)

Measure

:

At least one patient seen by the MIPS-eligible clinician during the performance period (or patient-authorized representative) views, downloads, or transmits their health information to a third party during the performance period.

Objective

:

Patient-specific Education

Measure

:

Patient-specific Education

Measure Description

:

The MIPS-eligible clinician must use clinically-relevant information from CEHRT to identify patient-specific educational resources and provide access to those materials to at least one unique patient seen by the MIPS-eligible clinician.

Objective

:

Secure Messaging

Measure

:

Secure Messaging

Measure Description

:

For at least one patient seen by the MIPS-eligible clinician during the performance period, a secure message was sent using the electronic messaging function of CEHRT to the patient (or the patient-authorized representative), or in response to a secure message sent by the patient (or the patient-authorized representative) during the performance period.

Objective

:

Health Information Exchange

Measure

:

Health Information Exchange

Measure Description

:

The MIPS-eligible clinician that transitions or refers their patient to another setting of care or health care clinician (1) uses CEHRT to create a summary of care record; and (2) electronically transmits the summary to a receiving health care clinician for at least one transition of care or referral.

Objective

:

Medication Reconciliation

Measure

:

Medication Reconciliation

Measure Description

:

The MIPS-eligible clinician performs medication reconciliation for at least one transition of care in which the patient is transitioned into the care of the MIPS-eligible clinician.

Objective

:

Public Health Reporting

Measure

:

Immunization Registry Reporting

Measure Description

:

The MIPS-eligible is in active engagement with a public health agency to submit immunization data.

ACI Measures Beginning in 2018

The following are available clinicians using 2015 CEHRT, or a combination of 2014 and 2015 edition CEHRT. They are required for all ECs beginning in 2018.

Objective

Measure

Measure Description

Objective

:

Protect Patient Health Information

Measure

:

Security Risk Analysis

Measure Description

:

Conduct or review a security risk analysis, including addressing the security (to include encryption) of ePHI data created or maintained by CEHRT, and implementing security updates, as necessary, and correct identified security deficiencies as part of the MIPS-eligible clinician’s risk management process.

Objective

:

Electronic Prescribing

Measure

:

e-Prescribing

Measure Description

:

At least one permissible prescription written by the MIPS-eligible clinician is queried for a drug formulary and transmitted electronically using CEHRT.

Objective

:

Patient Electronic Access

Measure

:

Provide Patient Access

Measure Description

:

For at least one unique patient seen by the MIPS-eligible clinician: (1) the patient (or the patient-authorized representative) is provided timely access to view online, download, or 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 Programming Interface (API) in the MIPS-eligible clinician’s CEHRT.

Objective

:

Patient-specific Education

Measure

:

The MIPS-eligible clinician must use clinically-relevant information from CEHRT to identify patient-specific educational resources and provide electronic access to those materials to at least one unique patient seen by the MIPS-eligible clinician.

Objective

:

Coordination of Care through Patient Engagement

 

 

Measure

:

Secure Messaging

Measure Description

:

For at least one unique patient seen by the MIPS-eligible clinician during the performance period, a secure message was sent using the electronic messaging function of CEHRT to the patient (or the patient-authorized representative), or in response to a secure message sent by the patient (or the patient-authorized representative) during the performance period.

Objective

:

View, Download, or Transmit (VDT)

Measure

:

During the performance period, at least one unique patient (or patient-authorized representative) seen by the MIPS-eligible clinician actively engages with the EHR made accessible by the MIPS-eligible clinician. A MIPS-eligible clinician may meet the measure if the patient (or patient-authorized representative): (1) views, downloads, or transmits to a third party their health information; or (2) accesses 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 CEHRT; or (3) a combination of (1) and (2).

Objective

:

Patient-generated Health Data

Measure

:

Patient-generated health data or data from a non-clinical setting is incorporated into the CEHRT for at least one unique patient seen by the MIPS-eligible clinician during the reporting period.

Objective

:

Health Information Exchange

 

Measure

:

Send a Summary of Care

Measure Description

:

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 clinician: (1) creates a summary of care record using CEHRT; and (2) electronically exchanges the summary of care record.

Objective

:

Request/Accept Summary of Care

Measure

:

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.

Objective

:

Clinical Information Reconciliation

Measure

:

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 MIPS-eligible 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; and (3) Current Problem List – Review of the patient’s current and active diagnoses.

Objective

:

Public Health and Clinical Data Registry Reporting

Measure

:

Immunization Registry Reporting

Measure Description

:

The MIPS-eligible clinician is in 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).