Last month, we looked at Improvement Activities (IA), one of the three performance categories in the Merit-based Incentive Payment System (MIPS), part of Medicare’s Quality Payment Program (QPP). We asked: What steps have you taken in your practice to increase access and improve quality, contain costs, and create a positive environment for your patients, your staff and you? Our approach was to take credit for what we do best.
This month, we are looking at Advancing Care Information (ACI) and the required measures in this performance category. Below are the required measures and some key questions regarding electronic documentation of patient care. The answers can be of great help in understanding how your practice is doing in Advancing Care Information, supporting improved patient engagement, and connectivity.
How safe is your electronic health record system? The greatest threat to cyber security is an organization’s employees. So how are you and your staff doing with protecting passwords and controlling access? Working with your vendor to regularly monitor and review system use will alert you to in-house as well as external threats. E-Prescribing can be a boon, increasing speed, reducing paperwork, and eliminating handwriting challenges. But it has not eliminated the need for the same attention to precision and accuracy that writing prescriptions by hand requires. As we noted last time, the Prescription Drug Monitoring Program in your state -- C.U.R.E.S. in California -- is an invaluable safety net in protecting patients and physicians from inappropriate prescribing of controlled substances.
How are you responding to the wide variation in the willingness or comfort of patients to use electronic communications with you and your office? The variation is not always due to age or previous unfamiliarity with personal devices. Improving patient access is one of the Quadruple Aims. For each practice and each physician, the structure and function of electronic access by patients will be tailored to that practice’s culture. Appropriate safeguards, informed consent, and shared expectations regarding the type of information that can be shared must be in place.
Closing the communication loop on referrals is a continuing challenge. When a patient is referred from one physician to another, what information goes with or is sent on behalf of the patient? When the patient returns, what information comes with her? Meeting this challenge is a key element in achieving an effective transition of care between practitioners. What process for follow-up and follow-through do you have in your practice? How consistently is your process implemented? Is this coordination of care reflected in (a) improved patient understanding of the plan of care; (b) improved adherence to the plan; and (3) an improved outcome?
The information below regarding reporting Advancing Care Information data is taken from the Quality Payment Program web site. In 2017, there are two measure set options for reporting. The option you use to submit your data is based on your electronic health record edition.
- Option 1: Advancing Care Information Objectives and Measures
- Option 2: 2017 Advancing Care Information Transition Objectives and Measures
You can report the Advancing Care Information Objectives and Measures:
- If you have technology certified to the 2015 Edition; or
- If you have a combination of technologies from 2014 and 2015 Editions that support these measures.
You can report the 2017 Advancing Care Information Transition Objectives and Measures:
- If you have technology certified to the 2015 Edition; or
- If you have technology certified to the 2014 Edition; or
- If you have a combination of technologies from 2014 and 2015 Editions.
| Required Measure | Advancing Care Information Objectives and Measures |
2017 Advancing Care Information Transition Objectives and Measures |
|
Security Risk Analysis |
Conduct or review a security risk analysis in accordance with the requirements in 45 CFR 164.308(a)(1), including addressing the security (to include encryption) of ePHI data created or maintained by certified EHR technology in accordance with requirements in 45 CFR164.312(a) (2)(iv) and 45 CFR 164.306(d)(3), and implement security updates as necessary and correct identified security deficiencies as part of the MIPS eligible clinician's risk management process. | Conduct or review a security risk analysis in accordance with the requirements in 45 CFR 164.308(a)(1), including addressing the security (to include encryption) of ePHI data created or maintained by certified EHR technology in accordance with requirements in 45 CFR164.312(a) (2)(iv) and 45 CFR 164.306(d)(3), and implement security updates as necessary and correct identified security deficiencies as part of the MIPS eligible clinician's risk management process. |
| e-Prescribing | At least one permissible prescription written by the MIPS eligible clinician is queried for a drug formulary and transmitted electronically using certified EHR technology. | At least one permissible prescription written by the MIPS eligible clinician is queried for a drug formulary and transmitted electronically using certified EHR technology. |
|
Provide Patient Access |
For at least one unique patient seen by the MIPS eligible clinician: (1) The patient (or the patient authorized representative) is provided timely access to view online, download, and transmit his or her health information; and (2) The MIPS eligible clinician ensures the patient's health information is available for the patient (or patient-authorized representative) to access using any application of their choice that is configured to meet the technical specifications of the Application Programming Interface (API) in the MIPS eligible clinician's certified EHR technology. | At least one patient seen by the MIPS eligible clinician during the performance period is provided timely access to view online, download, and transmit to a third party their health information subject to the MIPS eligible clinician's discretion to withhold certain information. |
| Send a Summary of Care Request/Receive a Summary of Care; in 2017 Health Information Exchange |
For at least one transition of care or referral, the MIPS eligible clinician that transitions or refers his or her patient to another setting of care or healthcare provider: (1) creates a summary of care record using certified EHR technology; and (2) electronically exchanges the summary of care record. For at least one transition of care or referral received or patient encounter in which the MIPS eligible clinician has never before encountered the patient, the MIPS eligible clinician receives or retrieves and incorporates into the patient's record an electronic summary of care document. |
The MIPS eligible clinician that transitions or refers their patient to another setting of care or healthcare clinician: (1) uses CEHRT to create a summary of care record; and (2) electronically transmits such summary to a receiving healthcare clinician for at least one transition of care or referral. |
We hope you find this information helpful as you pick your pace for the first year of MIPS and chart your course to success.
Sources: Advancing Care Information. https://qpp.cms.gov/measures/aci. Accessed June 1, 2017.
Bradley, C., Medicare Quality Payment Program 2017 and Beyond. CAMGMA, April 28, 2017.
Carole Lambert is Vice President, Practice Optimization for CAP. Questions or comments related to this article may be sent to clambert@CAPphysicians.com.