The MACRA Quality Payment Program final rule, released Oct. 14, finalizes the payment programs for physicians under MACRA’s Advanced Alternative Payment Models (APMs) and the Merit-Based Incentive Payment System (MIPS), beginning January 1, 2017.
Advancing Care Information (ACI) replaces the Meaningful Use program for Medicare providers. The good news is that the number of measures to be reported has been reduced from 18 in the Meaningful Use program, to 11 in the proposed rule, to 5 in the final rule. In addition, it is no longer an ‘all-or-nothing’ incentive program, meaning that providers can now get credit for their partial success with the measures.
Advancing Care Information Measures
The required measures include: security risk analysis, e-prescribing, providing patient access, sending a summary of care and requesting and accepting a summary of care. The rule no longer requires reporting on measures for clinical decision support and computerized provider order entry. In some ways, the program is focusing on harder measures, but ones that are felt to help achieve better outcomes. Additionally, different measures are available depending on the certification edition of your CEHRT (2014 or 2015). [View all ACI measures]
In 2017, physicians have the option of reporting for a 90-day period instead of a full year to avoid a negative payment adjustment, which can be more tenable for many providers. Reporting all required ACI measures will be considered sufficient for avoiding the MIPS negative payment adjustment.
Advancing Care Information Submission Methods
Advancing Care Information measures can be submitted via qualified registry, QCDR, EHR, CMS web-interface (groups only) or attestation. It’s important to note that the measures to be tracked are predicated on interoperability, e.g. sending and receiving a summary of care through EHRs. Interoperability-related measures have been part of the Meaningful Use program, however, they can present a challenge, in that they can be outside the control of the physician. Note that if an EHR is not architected to enable cross-continuum care coordination and connectedness, its users will not be able to successfully report the ACI Performance Category of MIPS. Besides reporting through your EHR, you can also report ACI measures successfully through a QCDR, qualified registry, attestation or the CMS web interface.
The sense is that CMS Acting Administrator Andy Slavitt is making a concerted effort to make the program meaningful for practitioners. "As we implement the Quality Payment Program under MACRA, we cannot do it without making a sustained, long-term commitment to take a holistic view on the demands on the physician and clinician workforce," Slavitt said when the initiative was announced Thursday.
Citations
[1] The Department of Health and Human Services. (2016, Oct. 14). Executive Summary; Medicare Program; Merit-based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models. Retrieved from https://qpp.cms.gov/docs/QPP_Executive_Summary_of_Final_Rule.pdf
[2] Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Final Rule, 42 CFR § 414 (2016). [CMS-5517-FC]
[3] Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Proposed Rule, 42 CFR § 414 (2016).
