Home > EHR, meaningful use, Medicare > Advancing Care Information in MIPS: Reweighting to Zero

Advancing Care Information in MIPS: Reweighting to Zero

The Advancing Care Information (ACI) category in the Merit-Based Incentive Payment System (MIPS) can be “reweighted to zero” under certain circumstances. This is functionally similar to obtaining an exclusion from the ACI portion of MIPS.  If ACI is reweighted to zero, the category’s full weight (25% of the MIPS final score) is then reallocated to the Quality category (with an exception I won’t dive into here).

The various options to reweight ACI to zero are essentially based on the eligibility criteria and the significant hardship exception options that were present in the Medicare EHR Incentive Program (or “Meaningful Use”).

  1. Non-patient-facing (NPF) MIPS eligible clinicians will have their ACI category automatically reweighted to zero by CMS. The agency will determine them to be NPF if they have fewer than 100 “patient-facing encounters” during the corresponding determination period. In terms of group reporting, a group would be “non-patient-facing” if more than 75 percent of the NPIs billing under that group’s TIN meet the NPF definition. The specific patient-facing encounter codes have not yet been identified publicly by CMS, but we are told the agency could release that code list as early as this month, or perhaps even notify participants of their NPF determination before the code list itself is released…  Stay tuned…
  2. Hospital-based MIPS eligible clinicians will also have the ACI category automatically reweighted to zero by CMS. Hospital-based ECs are those who provide 75 percent or more covered professional services in the inpatient hospital (POS 21), on campus outpatient hospital (POS 22), or emergency room (POS 23) settings. This is substantially different from the MU definition of “hospital-based” in that CMS lowered the threshold from 90 percent to 75 percent, and included POS Code 22 as a hospital setting.  Thus, many more physicians will end up being “hospital-based” under the MIPS/ACI definition than there were for MU.
  3. Non-physician MIPS eligible clinicians (nurse practitioners, physician assistants, etc.) will also have ACI reweighted to zero if they choose not to report any ACI data.
  4. Other MIPS eligible clinicians not covered by bullets #1-3 above can manually apply to reweight ACI to zero if they meet any of the following criteria (based on the corresponding MU significant hardship exceptions):
    • Insufficient broadband availability
    • Faced extreme and uncontrollable circumstances 
    • Lacked influence over certified EHR technology availability
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Categories: EHR, meaningful use, Medicare
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