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2018 ACI Measure Exclusions: HIE and eRX

The CMS 2018 Final Rule for the Quality Payment Program has approved exclusions for some of the Advancing Care Information (ACI) measures. Make sure you’re taking advantage of exclusions you may be eligible for by referencing our tables provided below. Importantly, these exclusions also apply retroactively to the 2017 performance year as well. Details can be found in the final rule on pp. pp. CMS-5522-FC 398 to CMS-5522-FC 402.

If you are attesting to the 2017 or 2018 Transition Measures Using a 2014 CEHRT:

 

Measure Name Numerator Denominator Exclusion
e-Prescribing The number of prescriptions in the denominator generated, queried for a drug formulary, and transmitted electronically using CEHRT. The number of prescriptions written for drugs requiring a prescription in order to be dispensed other than controlled substances during the performance period; OR the number of prescriptions written for drugs requiring a prescription in order to be dispensed during the performance period. Any MIPS EC who writes fewer than 100 permissible prescriptions during the performance period.
Health Information Exchange The number of transitions of care and referrals in the denominator where a summary of care record was created using CEHRT and exchanged electronically. The number of transitions of care and referrals during the performance period for which the MIPS EC was the transferring or referring health care provider. Any MIPS EC who transfers a patient to another setting or refers a patient fewer than 100 times during the performance period.

 

If you are attesting to the 2017 or 2018 Standard Measures Using a 2015 CEHRT:

 Measure Name  Numerator  Denominator  Exclusion
e-Prescribing The number of prescriptions in the denominator generated, queried for a drug formulary, and transmitted electronically using CEHRT. The number of prescriptions written for drugs requiring a prescription in order to be dispensed other than controlled substances during the performance period; OR the number of prescriptions written for drugs requiring a prescription in order to be dispensed during the performance period. Any MIPS EC who writes fewer than 100 permissible prescriptions during the performance period.
Send a Summary of Care The number of transitions of care and referrals in the denominator where a summary of care record was created using CEHRT and exchanged electronically. The number of transitions of care and referrals during the performance period for which the MIPS eligible clinician was the transferring or referring clinician. Any MIPS EC who transfers a patient to another setting or refers a patient fewer than 100 times during the performance period.
Request/Accept a Summary of Care The number of patient encounters in the denominator where an electronic summary of care record received is incorporated by the clinician into the CEHRT. The number of patient encounters during the performance period for which a MIPS eligible clinician was the receiving party of a transition or referral or has never before encountered the patient and for which an electronic summary of care record is available. Any EC who receives transitions of care or referrals or has patient encounters in which the EC has never before encountered the patient fewer than 100 times during the performance period.

FAQ:

Q. What if I qualify for an exclusion but I want to report the measure?

A. Any MIPS eligible clinician (EC) may claim these exclusions if they qualify, although they are not required to claim the exclusions and may report on the measures if they choose.

Q. In which reporting years are these exclusions available for use?

A. As outlined in the 2018 Final Rule, these exemptions are for both the 2017 and 2018 reporting years.

Q. How do the exclusions for individual providers apply when reporting as a group?

A. MIPS eligible clinicians may claim the exclusions if reporting as a group. The group will need to aggregate data for all individual ECs within the group for whom they have data in the CEHRT.  If an individual EC meets the criteria to exclude a measure, you can exclude that EC’s data from the calculation of that particular measure only.

Q. What if we really have more than 100 transitions of care, but our EHR workflow is capturing less than 100 because it is not set up correctly?

A. When it comes to an audit, the EHR is considered by CMS to be the source of truth. However, if your EHR is not capturing the transitions of care correctly and you truly have more than 100 transitions of care, best practice would be to implement any corrections by October 1st, so the EHR will accurately reflect your transitions of care by the final 90-day reporting period.  This may involve an operational workflow change or working with your vendor to troubleshoot the report, depending on what is causing the discrepancy.

Related Definitions:

Prescription – The authorization by a MIPS eligible clinician to dispense a drug that would not be dispensed without such authorization.

Permissible Prescriptions – All drugs meeting the definition of a prescription and may include electronic prescriptions of controlled substances where the creation of an electronic prescription for the medication is feasible using CEHRT and where allowed by law in the jurisdiction where the clinician provides care.

Transition of Care – The movement of a patient from one setting of care (hospital, ambulatory primary care practice, ambulatory specialty care practice, long-term care, home health, rehabilitation facility) to another. At a minimum, this includes all transitions of care and referrals that are ordered by the MIPS eligible clinician.

Current Problem Lists – At a minimum, a list of current and active diagnoses.

Active/Current Medication List – A list of medications that a given patient is currently taking.

Active/Current Medication Allergy List – A list of medications to which a given patient has known allergies.

Allergy – An exaggerated immune response or reaction to substances that are generally not harmful.

Care Plan – The structure used to define the management actions for the various conditions, problems, or issues. A care plan must include at a minimum the following components: problem (the focus of the care plan), goal (the target outcome), and any instructions that the MIPS eligible clinician has given to the patient. A goal is a defined target or measure to be achieved in the process of patient care (expected outcome).

Summary of Care Record – All summary of care documents used to meet this measure must include the following information if the MIPS eligible clinician knows it:

  • Patient Name
  • Referring or transitioning healthcare provider’s name and office contact information (MIPS eligible clinician only)
  • Procedures
  • Encounter diagnosis
  • Immunizations
  • Laboratory test results
  • Vital signs (height, weight, blood pressure, BMI)
  • Smoking status
  • Functional status, including activities of daily living, cognitive, and disability status
  • Demographic information (preferred language, sex, race, ethnicity, date of birth)
  • Care plan field, including goals and instructions
  • Care team including the primary care provider of record and any additional known care team members beyond the referring or transitioning provider and the receiving provider
  • Reason for referral (MIPS eligible clinician only)
  • Current problem list (providers may also include historical problems at their discretion)
  • Current medication list
  • Current medication allergy list

 

Questions about these exclusions and whether or not they apply to you? Contact one of our knowledgeable Consultants today, or add your question in the comment section below.

Looking for more information about the ACI Category of MIPS?

You can find information about reporting requirements in our resources below:

Blog Post – ACI: What You Need to Know for 2017

Webinar: The 2018 Final Rule – in Plain English with Dr. Dan Mingle

 

Your guide to changes for MIPS Reporting in 2018

This free guide provides an overview of key changes to MIPS for 2018 and what you can do now to get started!

Download the Guide

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