QPP UPDATE: How the Scoring for Various Elements of the MIPS Categories will be Handled

News | Published: Thursday, April 27, 2017 5:00 am


 

Among the new items recently released from the Centers for Medicare and Medicaid (CMS) on the Merit-based Incentive Payment System (MIPS), there are some details on Advancing Care Information (ACI) that will impact many in the MedAxiom community. We are providing explanations of those new details below and suggest you reference the following Quality Payment Program (QPP) fact sheet https://qpp.cms.gov/docs/QPP_ACI_Fact_Sheet.pdf for more information as needed.

 

1. ACI Performance Category Reweighting

MIPS Eligible Clinicians (EC) must use Certified Electronic Health Records Technology (CEHRT) to report to the ACI Performance Category. Under certain circumstances,  a MIPS EC can have this category re-weighted to 0% so that is not included in their total score. If a MIPS EC meets one of three criteria, the ACI weighting of 25% will be reassigned to the Quality performance category, allowing them the chance to get the 100 points under MIPS. 

A MIPS EC may apply for reweighting for the following reasons:

  • Insufficient internet connectivity
  • Extreme and uncontrollable circumstances
  • Lack of control over the availability of CEHRT

(Note:  Simply lacking CEHRT is not sufficient for reweighting.)

Currently, CMS has not yet made information about the application available. When this information is available, CMS will notify the MIPS community via email through their QPP Email Updates (subscription available at qpp.cms.gov at the bottom of the web page).

The following types of MIPS ECs qualify for automatic reweighting:

  • Hospital-based MIPS EC (defined as an EC who furnishes 75% or more of their covered professional services in Place of Service (POS) codes 21, 22, and 23 as an inpatient hospital, on campus outpatient hospital or emergency room setting in the year preceding the performance period).
  • Physician Assistants
  • Nurse Practitioners
  • Clinical Nurse Specialists
  • CRNAs
  • Clinicians who lack face-to-face interactions with patients

These MIPS ECs can still choose to report if they would like, and if data is submitted, CMS will score their performance and weight their ACI performance category accordingly.

 

2. Base Score

In order to get any score in ACI, ECs need to meet the base score requirements.  To meet the requirements, ECs must answer “Yes” to the Security Analysis Measure (regardless of measure set), and have at least 1 patient in the remaining measures.

For Advancing Care Information Measures, these include:

  • e-prescribing
  • Provide patient access
  • Send a summary of care
  • Request/accept summary of care

For the 2017 ACI Transition measures, these include:

  • e-prescribing
  • Provide patient access
  • Send a summary of care
  • Health information exchange 

As long as the EC has 1 patient who meets the criteria for each of the applicable measure set, the EC will meet the base score requirement, which is 50% of the total score.  Not meeting these requirements will result in a 0 score for the ACI performance category.

 

3. Bonus Score

The bonus score is based on reporting the following:

  • Reporting “Yes” to 1 or more additional public health and clinical data registries beyond the immunization registry reporting measure (worth a 5% bonus).
  • Reporting “Yes” to the completion of at least 1 of the specified Improvement Activities using CEHRT (worth a 10% bonus).

 

By Timothy W. Kennedy, Attorney
Hall Render
tkennedy@hallrender.com

For more information on this topic, visit our MACRA Resource Page here: https://www.medaxiom.com/macra.