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.
In 2018, CMS finalized a Small Practice exception which excepts eligible clinicians who are part of a practice with 15 or fewer clinicians.
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:
- Insufficient Internet Access (Practicing in an area without sufficient Internet access or facing insurmountable barriers to obtaining infrastructure, such as a lack of broadband access)
- Extreme and Uncontrollable Circumstances (Natural disasters, practice or hospital closure, severe financial distress, EHR certification/vendor issues).
- Lack of Control over the Availability of CEHRT (Inability to control CEHRT availability in over 50% of patient encounters)
For the 2018 performance year, these hardship applications are due on December 31, 2018.