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  • Kyle Meadors

CMS Reporting Rules - MIPS vs MU


Lost amidst the long awaited MIPS/APM Incentive rule and long overdue 21st Century Cures Act, CMS also dropped their Medicare hospital outpatient prospective payment system and the Medicare ambulatory surgical center payment system Final Rule (OPPS/ASC). Within this, CMS introduced some changes to some of their EHR Incentive Program which impacts both providers and developers, including changes to the required measures and reporting period.

You can read a good summary of this rule, including changes to the EHR Incentive Program, on this CMS press release. However, this now essentially gives us four alternative CMS quality programs in terms of different required measures or reporting periods depending on the setting and billing aspect of the providers.

I believe CMS would say there are three different quality payment programs: EHR Incentive Program (i.e., MU), MIPS Incentive Program, and Advance APMs. Advanced APMs are a whole different subject so we can ignore them for now.

However of those two remaining ones, you can actually subdivide them a few other ways. MIPS is exclusive to eligible providers (EPs) and now eligible clinicians (ECs) for federal Medicare billing. Medicaid from the states is covered by the EHR Incentive Program.

Also, eligible hospitals and critical access hospitals (EHs/CAHs) are only covered by EHR Incentive Program. EHs/CAHs have slightly different public health related measures than EPs or ECs do.

For most developers, these differences are not a major deal as the programs' various requirements for CEHRT are more similar than not. The measures are generally the same and thus the necessary ONC criteria (for either with 2014 Edition or 2015 Edition) to meet the measures is very similar across all programs.

Likely the biggest impact is that currently (and CMS may later change this) EHR Incentive Program reporting period for CY 2018 is full 12 months while MIPS ACI reporting in CY 2018 is just consecutive 90 days. If developers knew that their customers were ONLY qualifying for Medicare and not Medicaid thresholds, then their 2015 Edition HIT systems would not need to be released until later in CY 2018.

Also, strangely CMS allowed CDS and CPOE measures to remaining in the Medicaid program. It is not really clear to me why they would keep them given they are no longer measures for the other programs.

Below is a "simple" breakdown of the core differences, and yes the quotes is suppose to imply sarcasm. However, it is written to make comparison of the programs a bit easier. While lengthy, it does give a snapshot of general requirements. Still, even as I write it I am struck by how confusing CMS has made this, but that is why Chart Lux is here: to help developers navigate this confusion. Let us know if we can help more.

  • MIPS ACI Incentive Program (EPs - Medicare)

  • CY 2017

  • CEHRT:

  • 2014 Edition or 2015 Edition.

  • Reporting Period:

  • Consecutive 90 Days.

  • Measures:

  • Security Risk (Base), eRx (Base), Patient Access (Base), Send Summary of Care (Base), Request/Accept Summary of Care (Base), Patient Education, VDT, Secure Messaging, Patient-Generated Health Data (2015 Edition only), CIRI (2014 Edition only does Medication Reconciliation), Public Health.

  • Public Health Measures:

  • 2015 Edition:

  • Immunization (Performance), Syndromic (Bonus), Electronic Case (Bonus), Public Health Registry (Bonus), Clinical Data Registry (Bonus).

  • 2014 Edition:

  • Immunization (Performance), Syndromic (Bonus), and Specialized Registry (Bonus).

  • Which Measure are Absolutely Required:

  • Just Base Measures and only need “1” in numerator of those Base Measures to qualify.

  • Measure Exclusions Allowed:

  • No.

  • Scoring Methodology:

  • All Base Measures equals 50 points and then percentage of other Performance Measures totaled along with Measure bonus points.

  • CY 2018

  • CEHRT:

  • 2015 Edition.

  • Reporting Period:

  • Consecutive 90 Days.

  • Measures:

  • Security Risk (Base), eRx (Base), Patient Access (Base), Send Summary of Care (Base), Request/Accept Summary of Care (Base), Patient Education, VDT, Secure Messaging, Patient-Generated Health Data, CIRI, Public Health.

  • Public Health Measures:

  • Immunization (Performance), Syndromic (Bonus), Electronic Case (Bonus), Public Health Registry (Bonus), Clinical Data Registry (Bonus).

  • Which Measure are Absolutely Required:

  • Just Base Measures and only need “1” in numerator of those Base Measures to qualify.

  • Measure Exclusions Allowed:

  • No.

  • Scoring Methodology:

  • All Base Measures equals 50 points and then percentage of other Performance Measures totaled along with Measure bonus points.

  • EHR Incentive Program (EPs - Medicaid)

  • CY 2017 (Modified Stage 2 or Stage 3)

  • CEHRT:

  • 2014 Edition or 2015 Edition.

  • Reporting Period:

  • Consecutive 90 Days.

  • Measures:

  • CPOE, CDS, Security Risk, eRx, Patient Access, Send Summary of Care, Request/Accept Summary of Care, Patient Education, VDT, Secure Messaging, Patient-Generated Health Data (2015 Edition only), CIRI (2014 Edition only does Medication Reconciliation), Public Health.

  • Public Health Measures:

  • 2015 Edition:

  • Immunization, Syndromic, Electronic Case, Public Health Registry, Clinical Data Registry.

  • Meet two (2) public health measures (exclusions are also available); multiple different Public Health Registries and Clinical Data Registries can be used to get to this number.

  • 2014 Edition:

  • Immunization, Syndromic, Specialized Registry.

  • Meet two (2) public health measures (exclusions are also available).

  • Which Measure are Absolutely Required:

  • All of them via threshold or exclusions.

  • Measure Exclusions Allowed:

  • Yes – measure specific.

  • Scoring Methodology:

  • If all non-excluded measures meet their required threshold, it “passes”. If just one non-excluded measure does not meet the required threshold, it “fails”.

  • CY 2018 (Stage 3 for everyone)

  • CEHRT:

  • 2015 Edition.

  • Reporting Period:

  • Full calendar year.

  • Measures:

  • CPOE, CDS, Security Risk, eRx, Patient Access, Send Summary of Care, Request/Accept Summary of Care, Patient Education, VDT, Secure Messaging, Patient-Generated Health Data, CIRI, Public Health.

  • Public Health Measures:

  • Immunization, Syndromic, Electronic Case, Public Health Registry, Clinical Data Registry.

  • Meet two (2) public health measures (exclusions are also available); multiple different Public Health Registries and Clinical Data Registries can be used to get to this number.

  • Which Measure are Absolutely Required:

  • All of them via threshold or exclusions.

  • Measure Exclusions Allowed:

  • Yes – measure specific.

  • Scoring Methodology:

  • If all non-excluded measures meet their required threshold, it “passes”. If just one non-excluded measure does not meet the required threshold, it “fails”.

  • EHR Incentive Program (EHs/CAHs - Medicare)

  • CY 2017 (Modified Stage 2 or Stage 3)

  • CEHRT:

  • 2014 Edition or 2015 Edition.

  • Reporting Period:

  • Consecutive 90 Days.

  • Measures:

  • Security Risk, eRx, Patient Access, Send Summary of Care, Request/Accept Summary of Care, Patient Education, VDT, Secure Messaging, Patient-Generated Health Data (2015 Edition only), CIRI (2014 Edition only does Medication Reconciliation), Public Health.

  • Public Health Measures:

  • 2015 Edition:

  • Immunization, Syndromic, Electronic Case, Public Health Registry, Clinical Data Registry, Electronic Reportable Laboratory Results.

  • Meet three (3) public health measures (exclusions are also available); multiple different Public Health Registries and Clinical Data Registries can be used to get to this number.

  • 2014 Edition:

  • Immunization, Syndromic, Specialized Registry, Electronic Reportable Laboratory Results.

  • Meet three (3) public health measures (exclusions are also available).

  • Which Measure are Absolutely Required:

  • All of them via threshold or exclusions.

  • Measure Exclusions Allowed:

  • Yes – measure specific.

  • Scoring Methodology:

  • If all non-excluded measures meet their required threshold, it “passes”. If just one non-excluded measure does not meet the required threshold, it “fails”.

  • CY 2018 (Stage 3 for everyone)

  • CEHRT:

  • 2015 Edition.

  • Reporting Period:

  • Full calendar year.

  • Measures:

  • Security Risk, eRx, Patient Access, Send Summary of Care, Request/Accept Summary of Care, Patient Education, VDT, Secure Messaging, Patient-Generated Health Data, CIRI, Public Health.

  • Public Health Measures:

  • Immunization, Syndromic, Electronic Case, Public Health Registry, Clinical Data Registry, Electronic Reportable Laboratory Results.

  • Meet three (3) public health measures (exclusions are also available); multiple different Public Health Registries and Clinical Data Registries can be used to get to this number.

  • Which Measure are Absolutely Required:

  • All of them via threshold or exclusions.

  • Measure Exclusions Allowed:

  • Yes – measure specific.

  • Scoring Methodology:

  • If all non-excluded measures meet their required threshold, it “passes”. If just one non-excluded measure does not meet the required threshold, it “fails”.

  • EHR Incentive Program (EHs/CAHs - Medicaid)

  • CY 2017 (Modified Stage 2 or Stage 3)

  • CEHRT:

  • 2014 Edition or 2015 Edition.

  • Reporting Period:

  • Consecutive 90 Days.

  • Measures:

  • CPOE, CDS, Security Risk, eRx, Patient Access, Send Summary of Care, Request/Accept Summary of Care, Patient Education, VDT, Secure Messaging, Patient-Generated Health Data (2015 Edition only), CIRI (2014 Edition only does Medication Reconciliation), Public Health.

  • Public Health Measures:

  • 2015 Edition:

  • Immunization, Syndromic, Electronic Case, Public Health Registry, Clinical Data Registry, Electronic Reportable Laboratory Results.

  • Meet four (4) public health measures (exclusions are also available); multiple different Public Health Registries and Clinical Data Registries can be used to get to this number.

  • 2014 Edition:

  • Immunization, Syndromic, Specialized Registry, Electronic Reportable Laboratory Results.

  • Meet three (3) public health measures (exclusions are also available).

  • Which Measure are Absolutely Required:

  • All of them via threshold or exclusions.

  • Measure Exclusions Allowed:

  • Yes – measure specific.

  • Scoring Methodology:

  • If all non-excluded measures meet their required threshold, it “passes”. If just one non-excluded measure does not meet the required threshold, it “fails”.

  • CY 2018 (Stage 3 for everyone)

  • CEHRT:

  • 2015 Edition.

  • Reporting Period:

  • Full calendar year.

  • Measures:

  • CPOE, CDS, Security Risk, eRx, Patient Access, Send Summary of Care, Request/Accept Summary of Care, Patient Education, VDT, Secure Messaging, Patient-Generated Health Data, CIRI, Public Health.

  • Public Health Measures:

  • Immunization, Syndromic, Electronic Case, Public Health Registry, Clinical Data Registry, Electronic Reportable Laboratory Results.

  • Meet four (4) public health measures (exclusions are also available); multiple different Public Health Registries and Clinical Data Registries can be used to get to this number.

  • Which Measure are Absolutely Required:

  • All of them via threshold or exclusions.

  • Measure Exclusions Allowed:

  • Yes – measure specific.

  • Scoring Methodology:

  • If all non-excluded measures meet their required threshold, it “passes”. If just one non-excluded measure does not meet the required threshold, it “fails”.

#CMS #meaningfuluse #CEHRT #MIPS #OPPSASC

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