The Centers for Medicare and Medicaid Services (CMS) has confirmed to ACR that eligible clinicians participating in the Advancing Care Information (ACI) category of the Merit-based Incentive Payment System (MIPS) will have a certain degree of flexibility to define “seen patients” for their ACI measures.
This flexibility — originally created for the EHR Incentive Program (Meaningful Use) via CMS FAQ #3307 — was meant to enable Meaningful Use (MU) participants to essentially customize their “seen patients” denominator used in several MU measures, provided the following parameters were met:
- All actual face-to-face encounters and telemedicine encounters were included
- At least some of the participants' provided services were included
- It was consistent for the full reporting period and across all relevant measures
In the MU program, this flexibility allowed radiologist participants to limit their “seen patients” definition to those who underwent specific services and/or were treated in specific locations. The policy ultimately made the MU measures more manageable with smaller, more focused denominators. The expectation is that continuing this flexibility into the ACI category of MIPS will do the same for ACI participants.
This flexibility is only relevant to active participants in ACI. Importantly, it does not have any effect on the “non-patient-facing” determination process or other ACI reweighting options discussed in ACR Clarifies ACI Options in MIPS. The vast majority of ACR members are expected to take advantage of one of the ACI reweighting options instead of participating in ACI.
Find more information about ACI options or refer to the ACR Be MACRA Ready webpage.
The above article is intended for informational purposes only and should not be used as a guidance or legal document. Members with questions about this article, or the topic in general, should please contact Michael Peters, ACR director of regulatory and legislative affairs, via email or by phone at 202-223-1670.