Medicare Compliance & Reimbursement

Tip: Don't throw away that 2014 Edition EHR just yet.

If you're planning on upgrading your Certified EHR Technology (CEHRT), you may be eligible for an incentive for your 2018 Advancing Care Information (ACI) measures reporting - that will significantly improve your 2020 pay and make the transition from "Pick-Your-Pace" to "Quality Payment Program Year 2" a whole lot easier.

Background: For Medicare Part B clinicians who are reimbursed through the Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs), Advancing Care Information ousts Meaningful Use as the required technical component for Medicare reimbursement and covers 25 percent of the MIPS composite score, which is what determines your eventual Medicare payment amount.

By far the most complicated and intricate of the categories, there were only two options for attestation in 2017 to avoid financial censure. And due to its complexity, the QPP final rule combined with CMS's promise to reduce provider burden shows only slight adjustments for the CY 2018 ACI requirements. This means a lighter load for practices worried about implementation and QPP Year 2 reporting.

2018 updates: However the biggest news to cheer about in 2018 concerns the CEHRT requirements. CMS is going to continue to allow practices to use their 2014 Edition CEHRT without penalty; however, a 10 percent bonus is available for clinicians who opt to upgrade or utilize the 2015 Edition.

Though your MIPS composite score in 2018 must still include 25 percent from ACI measures, CMS has lightened some issues under the technical component for QPP Year 2. Here's a quick overview of what's new for CY 2018 that will impact your 2020 Medicare pay:

• Opportunities to score bonuses ranging from 5 to 10 percent for reporting performance measures for a public health agency or clinical data registry.
• With the "authority of the 21st Century Cures Act," CMS will offer MIPS providers and small practices some ACI exceptions for hardship, the QPP fact sheet says.
• Due to the extenuating circumstances caused by Hurricanes' Harvey, Irma, and Maria, as well as the California Wildfires, the final rule offers a CEHRT hardship application with a deadline of Dec. 31, 2017 (transition year) and "automatically" weights "the Quality, Advancing Care Information, and Improvement Activities performance categories at 0% of the final score [for 2018] for clinicians impacted by Hurricanes' Irma, Harvey and Maria and other natural disasters."

Tip: Remember the EHR edition that you have will determine the option you report under and the measures you submit. 2015 Edition CEHRT and more sophisticated data will likely garner your practice a higher incentive, according to the final rule guidance.

For more information about Advancing Care Information, visit qpp.cms.gov/mips/advancing-care-information.