Health Information Compliance Alert

Published on Tue Dec 13, 2016 PDF

With two paths for success, MACRA’s new EHR requirements offer options for engagement.

As Meaningful Use (MU) rides off into the sunset and Advancing Care Information (ACI) emerges as the tech component under MACRA Quality Payment Program (QPP), eligible clinicians (EC) everywhere are encouraged to adopt some of the new requirements. For those who choose to ignore the transition, refusing to send in data for 2017, you can expect a negative 4 percent payment adjustment, CMS warns.

Quick review. Here is a short primer of what ACI is and means to you.

• You must report on five interoperability measures under ACI but can report more.
• Report your data for at least 90 days in 2017 to avoid a negative impact on your payment.
• There are incentives for care coordination, public health reporting, and more.
• This technological measure under the QPP allows for a customization to fit your practice needs.
• ACI caps at 100 percentage points and is weighted at 25 percent of your overall Merit-based Incentive Payment System (MIPS) score.

Two tracks for reporting. Under ACI, MACRA offers two pathways to report how you are adapting to the new CEHRT requirements. First, there’s the all-in list of 15 comprehensive objectives and measures, which is for providers already entrenched in MU-based practices and who can easily transition to ACI. The other option is a shorter list of just 11 measures and is for the 2017 ACI transition period only; these objectives are the ones most ECs will choose from for this first MIPS reporting period.

Here’s a Brief Overview of the 11 Measures to Know

Take a look at these ACI objectives and measures outlined in the QPP factsheets that you’ll have to choose from for your 2017 MACRA transition from MU to ACI:

1. e-Prescribing: MIPS requires that at least one prescription be written by an EC and transferred via CEHRT during the reporting period.
2. Immunization registry reporting: Under this, ECs are required to coordinate immunization efforts with a public health agency.
3. Health information exchange: This objective concerns the referral of a patient from one provider to another, and the requirement is two-part — the health record must be made with CEHRT and transmitted electronically to the receiving EC from the referring provider.
4. Medication reconciliation: This measure refers to medication and transitional care under MIPS ECs.
5. Patient-specific education: With this objective, providers must offer health-related resources to patients using CEHRT for specific clinical reasons.
6. Secure messaging: During the reporting period, MIPS ECs must show that they used secure messaging to send information to at least one patient using CEHRT.
7. Provide patient access: MIPS providers offer online access to at least one patient, including third-party access, at the ECs discretion.
8. Security risk analysis: Providers must perform an audit followed by improvements to practice security and safety of ePHI.
9. Specialized registry reporting: Under this important measure, MIPS ECs can earn a 5 percent bonus by reporting their specialized data to public health and clinical data agencies.
10. Syndromic surveillance reporting: This earns you another 5 percent bonus for reporting syndromic surveillance information to a public agency.
11. View, download, or transmit. This measure, also known as VDT for short, requires that at least one patient views, downloads, or transmits online data offered by the provider then transfers it to a third party.

Tip: If you plan on adopting MIPS in the new year, make sure that your EHR is up-to-speed and ready for the switch from MU to ACI, ensuring that your transition runs smoothly and your Medicare payments aren’t negatively affected. The ONC offers providers a handy look-up tool to see if their current EHRs are certified with both present requirements and ready for future Medicare updates. To check your practice EHR, go to https://chpl.healthit.gov/#/search.

For a more comprehensive review of the ACI measures and their value under the MIPS scoring system, visit https://qpp.cms.gov/measures/aci.