Dec 03, 2024
Is Your ACO Prepared to Report Promoting Interoperability Measures for All ACO Participants?
Written by Larry Katzovitz
Category:
Regulatory
Is Your ACO Prepared to Report Promoting Interoperability Measures for All ACO Participants?
In the 2024 PFS Final Rule, CMS aligned the former MSSP certified electronic health record technology (“CEHRT”) requirements with the MIPS Promoting Interoperability performance category reporting requirement to eliminate the burden of complying with two separate CEHRT program requirements.
Beginning on January 1, 2025*, all Medicare Shared Savings Program (MSSP) participants, regardless of track or Qualified Advanced APM Participant (QP) status, must
- Be meaningful users of Certified Electronic Health Record Technology (CEHRT),
- Report for Promoting Interoperability (PI) and
- Earn a PI score
There are important exclusions for clinicians that would otherwise be excluded from reporting MIPS data. Eligible Clinicians
Excluded clinicians must meet one or more the following criteria:
- Not exceeding the low volume threshold
- Being a non-patient facing clinician, hospital-based clinician, ASC-based clinician, or part of a small practice
- Having a hardship exception granted by CMS for a specific performance year
Link to ACO PI requirements and exclusions: 425.507 Incorporating PI
Most ACOs previously met the requirement to have either 50% or 75% of their eligible clinicians using CEHRT. The new rule is changing to require 100% PI participation. Meeting the lower threshold was easy for most ACOs. In 2025, getting 100% of APM participants to utilize a CEHRT may be challenging for organizations. As they say, one bad apple could spoil the bunch when 100% participation is required.
Important Good News
While the 100% requirement for ACO participants to report and receive a score for PI starts on January 1st, 2025, only a 180-day reporting period is required for MIPS. Technically, clinicians can be on CEHRT by July 1st, 2025, and still possibly meet the new ACO PI requirements.
*CMS had several policy proposals included in the CY 2024 PFS proposed rule. CMS finalized proposed policies, with a one-year delay. CMS is delaying implementation of these policies for one year to give ACOs time to work with their participants to meet this new requirement. For performance years beginning on or after January 1, 2025.
What Happens If an ACO Does Not Have 100% CEHRT Participation or They Have Eligible Clinicians That Do Not Report Data for PI in 2025 and Beyond?
An ACO’s performance on the MIPS Promoting Interoperability performance category does not impact the calculation of the ACO’s shared savings or shared losses. However, to be eligible to share in savings, ACOs are required to comply with all Shared Savings Program requirements, including the requirement to report the MIPS Promoting Interoperability performance category for the performance year.
We should expect disincentives in the future for ACOs not meeting the Promoting Interoperability reporting requirements.
What Must ACOs Publicly Report to Meet the Shared Savings Program Public Reporting Requirement?
For PY 2025 (publicly reported in the Fall 2026) and subsequent performance years, ACOs must publicly report:
- The total number of ACO participants, that are MIPS eligible clinicians, QPs, or Partial QPs and earn a MIPS performance category score for the MIPS Promoting Interoperability (and are not excluded as described above) for the applicable performance year, including:
- The number of ACO participants, that meet the requirements of 42 CFR § 425.507(a) and are not excluded under 42 CFR § 425.507(b) for the applicable performance year; and
- The number of ACO participants, excluded under 42 CFR § 425.507(b) that voluntarily reported and received a MIPS PI performance category score for the applicable performance year.
Clinicians who report and earn a MIPS PI performance category score of zero are considered “scored” for purposes of the Shared Savings Program requirement for ACOs to report the MIPS Promoting Interoperability performance category and must be included in the count of clinicians the ACO publicly reports.
Next Steps Each ACO Should Consider
- Inventory CEHRT usage by your ACO’s eligible clinicians. Are there clinicians not on CEHRT and prepared to participate in MIPS?
- Develop a plan to get clinicians requiring CEHRT on it as soon as possible. Keep in mind that July 1st, 2025 is the last day to begin a 2025 MIPS PI reporting period. July 1st, 2025 is just around the corner making it imperative to take action regarding CEHRT and PI requirements now.
- Work with your EHR vendor to contract for and implement their system for all required clinicians
- Develop a strategic plan to obtain and maintain 100% compliance from your eligible providers.
- Determine if third-party consultant expertise would be beneficial. Consultants can assist with strategic planning, EHR implementation, understanding PI requirements, PI data reporting options, and provide tips on how to improve PI scores.
Helpful FAQs from CMS: MIPS FAQs Shared Savings Program