The following questions and responses for the Promoting Interoperability (PI) MIPS component are based upon the CMS Final MACRA Rule and the CY 2018 updates to the QPP Final Rule.
ACI accounts for 25 percent of an eligible clinician’s MIPS Composite Score. For non-patient-facing eligible clinicians or those who meet the criteria for another exception, CMS will reweight the 25 percent to other MIPS performance categories.
Not all physician anesthesiologists must participate in the Advancing Care Information component of MIPS. There are several steps to determine whether an eligible clinician must attest.
First, there are several hardships exception categories that, if granted, automatically exempt a MIPS-eligible clinician from reporting the ACI component. CMS calls these exceptions “Special Status” and they are evaluated annually. ECs can check their participation status on the QPP MIPS Participation Status website.
Eligible clinicians should review their Special Status on the CMS Eligibility website to determine whether they are hospital-based. Hospital-based MIPS eligible clinicians are those who furnish 75 percent or more of their covered professional services in sites identified with Place of Service (POS) Codes 19 (Off campus outpatient hospital), 21 (Inpatient Hospital), 22 (On campus outpatient hospital), or 23 (Emergency room). If CMS determines the ECs are non-patient facing, no participation in ACI is required.
Additionally, attestation requirements depend on whether a clinician is non-patient facing. This category is based upon the types of services that an eligible clinician bills. If CMS determines the ECs are non-patient facing, no participation in ACI is required.
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.
Eligible clinicians who do not have an automatic exception may apply for a hardship exception, if applicable. There are significant hardship categories that your facilities may apply for on an annual basis. The hardship categories are:
In 2018, CMS finalized a Small Practice exception which excepts eligible clinicians who are part of a practice with 15 or fewer clinicians. This exception requires ECs to submit an application. For the 2019 performance year, these hardship applications are due on December 31, 2019.
Eligible clinicians can participate but note that if you do participate, you will be assessed and scored by CMS. If the eligible clinician does not meet the ACI base requirements, they will receive a 0 for the ACI performance category.
CMS has eliminated the base, performance and bonus scoring structure used in 2017 and 2018 performance years. CMS is now scoring eligible clinicians on a 100-point scale.
In 2019, MIPS-eligible clinicians must attest to four objectives consisting of five measures with 100 total possible points. In 2019, there are two additional measures under the e-Prescribing objective and ECs can receive 5 bonus points for each for a total of 10 possible bonus points.
For more information on scoring, check our MACRA PI Scoring page.
ASA has compiled a list of resources related to the implementation of electronic health records.
Eligible clinicians must use 2015 Edition CEHRT in the 2019 performance year.
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.
The Office of the National Coordinator for Health Information Technology (ONC) has developed a comprehensive database of certified EHR technology. As more versions of 2015 CEHRT become available, ONC will update this resource for those seeking to make EHR purchasing decisions. For additional questions, ONC can be reached by e-mail or by phone at (202) 690-7151.
Yes. If you choose to engage in group reporting, CMS will assess your group across all four MIPS performance categories.
