ACI Checklist

Advancing Care Information Attestation Checklist

For the 2018 reporting year, AQI is not collecting or submitting Advancing Care Information (ACI) data to CMS. MIPS-eligible clinicians (ECs) who are not sure whether they qualify for an exemption from the Advancing Care Information performance category or those who are considering participating in ACI should review the following steps for deciding the best path for possible ACI attestation and data submission.

Note: If practices are submitting quality and improvement activity MIPS component data as a group to AQI AND they are required to or elect to submit ACI data, they must then submit that ACI data as a group via a separate reporting mechanism or vendor.

STEP 1: Check your MIPS Participation Status on the Quality Payment Program (QPP) website.
Enter your 10-digit National Provider Identifier (NPI) number in the QPP site to determine whether you are exempt from MIPS. 

STEP 2: Check your Certified Electronic Health Record Technology (CEHRT) to determine which edition you have and plan to attest accordingly.
First, make plans to acquire, verify or update Certified Electronic Health Record Technology (CEHRT) to the correct edition. For the 2018 performance period, MIPS eligible clinicians can use EHR technology certified to the 2014 Edition, a combination of both 2014 and 2015 Editions or the 2015 Edition. 

If a MIPS eligible clinician switches from 2014 Edition to 2015 Edition CEHRT during the performance period, the data collected for the base and performance score measures should be combined from both the 2014 and 2015 Edition of CEHRT.

ECs using 2014 CEHRT should review the Advancing Care Information Transition Objectives and Measures as these measures are slightly different from objectives and measures for CEHRT 2015.

The Office of the National Coordinator for Health Information Technology (ONC) has developed a comprehensive database of certified EHR technology where ECs can check their CEHRT.

STEP 3: Determine whether you are a hospital-based MIPS eligible clinician.
CMS defines a hospital-based clinician as a MIPS-eligible clinician who furnishes 75% or more of his or her covered professional services in POS 19 (off-campus outpatient hospital), POS 21 (inpatient hospital), POS 22 (on-campus outpatient hospital), or POS 23 (emergency room).

ECs can check their status on the QPP MIPS Participation Status website. Hospital-based MIPS ECs will have their ACI category automatically reweighted to zero and those points shifted to the Quality component. Please note, those hospital-based ECs that wish to participate despite having the exemption may submit ACI data and will receive an ACI score even if they were not required to submit data. 

STEP 4: Determine whether you are a non-patient facing MIPS-eligible clinician.

ECs can check their status on the QPP MIPS Participation Status website. Non-patient facing MIPS ECs will have their ACI category automatically reweighted to zero and those points shifted to the Quality component. Please note, those non-patient facing ECs that wish to participate despite having the exemption may submit ACI data and will receive an ACI score if they were not required to submit data.

STEP 5: Determine whether you have other “Special Status” exceptions.

There is also an exception for Ambulatory Surgery Center-based eligible clinicians. CMS defines this as a MIPS eligible clinician who furnishes 75 percent or more of his or her covered professional services in sites of service identified by POS 24. ECs can check their status on the QPP MIPS Participation Status website.

STEP 6: Determine whether you qualify for additional exemptions and apply using the CMS Hardship Application

There are three additional exemptions from ACI that require submission of a CMS Hardship Application:

  1. Insufficient Internet Connection: (Practicing in an area without sufficient internet access or facing insurmountable barriers to obtaining infrastructure, such as a lack of broadband access)
  2. Extreme and Uncontrollable Circumstance: (Natural disasters, practice or hospital closure, severe financial distress, EHR certification/vendor issues)
  3. Lack of Control over the Availability of CEHRT: (Inability to control CEHRT availability in more than 50 percent of patient encounters)

In 2018, CMS finalized a Small Practice exception, which exempts eligible clinicians who are part of a practice with 15 or fewer clinicians. For the 2018 performance year, these hardship applications are due on December 31, 2018. If CMS grants one of these hardships, ECs will have their ACI category automatically reweighted to zero and those points shifted to the Quality component.

Those ECs who have an exemption from ACI in 2018 and do not wish to participate need not review Steps 7-10.

STEP 7: If you are participating in ACI, pick a performance period of at least 90 days.
ECs participating in ACI must attest to and submit at least 90 days of 2018 data to CMS.

STEP 8: Review the ACI Scoring Requirements and determine which score components are most applicable to you and your practice.
The ACI Score is composed of a Base Score (50 percent), a performance score (up to 90%) and bonus scores (up to 25 percent). Although ECs may score over 100 percent, the score is capped at 100 percent.

ECs must report all the base score measures successfully in order to receive any points in the ACI component. For more information on scoring, visit ASA Advancing Care Information Scoring.

To maximize their ACI scores, ECs should review the performance measures and bonus point opportunities and attest and submit data to those that are most applicable.

STEP 9: Choose your submission method and verify its capabilities.
ECs who are reporting as individuals can attest via:

  1. Attestation to CMS using the QPP website 
  2. Qualified Clinical Data Registry (QCDR) – CMS has compiled a list of 2018 CMS Approved QCDRs along with the performance categories supported by the QCDRs.
  3. Qualified Registry (QR) -  CMS has compiled a list of 2018 CMS Approved QRs along with the performance categories supported by the QRs.
  4. Electronic Health Record (EHR) - ECs should work with their EHR vendors to begin to collect the required data for submission.

Groups have the four options listed above for attestation. In addition, groups that register for the 2018 CMS Web Interface prior to the deadline can attest to Advancing Care via the CMS Web Interface.

For more information on Group Reporting versus Individual Reporting, QCDR and QR Reporting Requirements and other relevant considerations, please see the ASA MIPS Reporting – NACOR Page.

STEP 10: Submit your ACI data by March 31, 2019.

More ACI Information

You can also find CMS Resources here and ASA FAQs here for all things MACRA.