Note: CMS has changed the name of the advancing care information category to promoting interoperability. The category abbreviation has changed from ACI to PI.
Physicians who do not successfully report promoting interoperability may face future Medicare penalties.
- If you fail promoting interoperability in 2018, you could get a penalty, but it depends on how you perform in the other Merit-Based Incentive Payment System categories.
- You must complete the promoting interoperability category using certified electronic health record technology (CEHRT).
- In nearly all cases, an promoting interoperability hardship reweighting on your MIPS score requires you to apply for a hardship exception.
2017 Advancing Care Information Reweighting
The deadline to apply for a 2017 ACI hardship has passed.
2018 Promoting Interoperability Reweighting
Physicians facing hardships for 2018 can apply to have their promoting interoperability score reweighted to 0 percent of their MIPS final score. CMS will post the hardship application on its website in late August, 2018. The deadline to apply for an PI hardship reweighting is Dec. 31, 2018. Learn more about hardship reweighting.
- Lack of an EHR system alone won't qualify you to have your promoting interoperability score reweighted. But, that does not mean you will get a payment penalty if you are denied an PI hardship. You could still achieve a MIPS Final Score of up to 65 points without an EHR system: 50 points for quality and 15 points for improvement activities.
- If you qualify for a hardship reweighting:
Important note: If you receive a hardship reweighting and you report any promoting interoperability measures, CMS will nullify your hardship and score your promoting interoperability submission.
- CMS will move the 25 promoting interoperability percentage points to the quality performance category.
- This means that the quality category will be worth 75 percent of your MIPS Final Score.
Much like under meaningful use, CMS considers this hardship reweighting on a year-by-year basis. You must provide proof of the selected hardship.
If you are reporting as a group: If all of the MIPS-eligible clinicians within a group do not qualify for an automatic reweighting or do not submit an application for and receive a hardship exception, the group will not qualify for an automatic reweighting and will have to report on the promoting interoperability performance category.
For the 2018 performance year, CMS retained the meaningful-use hardships for promoting interoperability and added three additional hardships. Some hardships are automatic, some require applications.
Exceptions that require applications:
- Insufficient Internet activity – for clinician practices in an area without sufficient internet access or facing insurmountable barriers to obtaining infrastructure.
- Extreme and uncontrollable circumstances – including disaster, practice or hospital closure, severe financial distress (bankruptcy or debt restructuring), EHR certification/vendor issues (includes issues related to CMS’ delayed rulemaking).
- Lack of control over CEHRT availability.
- NEW! Small practice hardship* – for practices of fewer than 15 clinicians that can show that obtaining and maintaining CEHRT creates undue hardship for the practice.
- NEW! EHR decertification hardship – for clinicians who have an EHR system which was decertified during the performance year or the prior performance year. You can only claim this hardship for two consecutive years.
Automatic exceptions (no application required):
- Lack of face-to-face patient interaction* – Groups are considered non-patient facing if more than 75 percent of its clinicians have 100 or fewer patient-facing encounters (including Medicare telehealth services).
- Hospital-based clinician* – a MIPS-eligible clinician who furnishes 75 percent or more of his or her covered professional services in an inpatient hospital, on-campus outpatient hospital, off-campus outpatient hospital, or emergency room setting.
- ASC-based clinician* – a MIPS-eligible clinician who furnishes 75 percent or more of his or her covered professional services under place of service code 24 used in the HIPAA standard transaction based on claims for a period prior to the performance period as specified by CMS.
*To determine if you and/or your group qualifies for any of these special statuses, check the MIPS Participation Status Tool.