On June 20, 2017, the Centers for Medicare & Medicaid Services (CMS) released a proposed rule for the Quality Payment Program. At a whopping 1,058 pages long, this proposed rule provides updates for the second and future years of the Quality Payment Program, but CMS also folded in some changes that provide welcome relief to clinicians who are struggling with the Advancing Care Information (ACI) performance category this year.
Before diving into the 2017-specific changes, please remember that this is still a proposed rule. CMS is soliciting everyone’s feedback–both things you like and things you don’t like so much—and they are giving us until August 21 to submit our comments before the rule is finalized during 4Q2017. Now that’s out of the way, let’s review a few ACI category changes. For your convenience, I have also cross-referenced the page(s) in the proposed rule (denoted with ) where you find each change discussed.
#1: You can use the “2017 Transition Objectives and Measures” to earn an ACI category score this year and next
What we have come to know as the “2017 Advancing Care Information Transition Objectives and Measures” was tweaked in the proposed rule to include the word “2018.” That small addition equates to big news because it means MIPS eligible clinicians can use 2014 CEHRT this year and next to earn an ACI category score [p201-203]. Yes, you can argue that this shouldn’t have made my 2017 list because it is a proposed change for the 2018 performance period, but I chose to include it because it alleviates the stress of having to upgrade to 2015 CEHRT this year.
#2: New e-prescribing exclusion means clinicians won’t have to forfeit their ACI category score
The Quality Payment Program final rule lacked exclusions for ACI measures, causing severe angst among MIPS eligible clinicians who write few prescriptions and are accustomed to the Meaningful Use exclusion. CMS has since realized their oversight, and thus added to the Quality Payment Program proposed rule a provision that would allow MIPS eligible clinicians who write fewer than 100 prescriptions to claim exclusion for this ACI base measure. Again, a small change but a big win for clinicians who otherwise would have had to accept a zero for their ACI category score because they couldn’t meet this one measure. If finalized, this policy change would be effective beginning with the 2017 performance period and is available to users of 2014 and 2015 CEHRT [p210-212].
#3: New Health Information Exchange (HIE) exclusion , too
Ditto for the HIE measure and lack of comparable Meaningful Use exclusion in the Quality Payment Program final rule. The proposed rule includes a HIE exclusion that could be claimed by MIPS eligible clinicians who transfer or refer patients fewer than 100 times during the performance period. This policy change would be effective beginning with the 2017 performance period and is available to users of 2014 and 2015 CEHRT [212-214].
#4: New exception in the event your EHR vendor loses the “C” in their CEHRT
ONC’s Certified Health IT Product List (CHPL) website underwent a facelift recently whereby visitors can now get a bird’s eye view of the health IT products and vendors that are under corrective action, were decertified, or (gasp) banned. If in the future you find your vendor/product listed on ONC’s decertified page, have no fear! The Quality Payment Program proposed rule would allow MIPS eligible clinicians to apply to have their ACI category reweighted to zero. To qualify, you would need to be using CEHRT that is decertified during the current performance period or the year prior [225-228].
Still on the fence about participating in Quality Payment Program during 2017? Heed my warning: If you are deemed MIPS eligible and you report absolutely nothing this year, you will automatically be subjected to a negative 4 percent payment adjustment for Medicare Part B items and services that you bill in 2019. Participating in the Quality Payment Program 2017 Transition Year is easy, and atom Alliance is here to help with technical assistance at o cost to you. Follow this link to ask a question or join the community of providers.
Sue Anderson-Lenz comes to Qsource with more than 25 years of IT experience, 15 of those years leading and managing programs, projects and change management initiatives. She holds a Master of Science in Computer Science and Master of Science in Health Information Management and has extensive experience with HL7, health IT interoperability and healthcare data analytics.