In continuing our efforts to understand the most important aspects of the Merit-based Incentive Payment System (MIPS), this month’s installment of Practice Points reviews the intent and reporting process for “Information Blocking.”
Guidance for this column was found within the QPP Fact Sheet entitled “The Merit-based Incentive Payment System (MIPS) Advancing Care Information Prevention of Information Blocking Attestation: Making Sure EHR Information Is Shared.”1 For the full document, please visit www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/ACI-Information-Blocking-fact-sheet.pdf.
To prevent actions that block the exchange of health information, the Medicare Access and CHIP Reauthorization Act of 2015 and the Quality Payment Program (QPP) final rule require MIPS-eligible clinicians to show that they have not knowingly and willfully limited or restricted the compatibility or interoperability of their certified electronic health record technology (CEHRT). The MIPS-eligible clinician can show that he/she is meeting this requirement by attesting to three statements about how their CEHRT is implemented and used. Together, these three statements are referred to as the “Prevention of Information Blocking Attestation.” Here are some frequently asked questions about this attestation and information blocking.
Q: Do I have to attest?
A: If you are a MIPS-eligible clinician who reports on the advancing care information performance category, then you must complete the Prevention of Information Blocking Attestation.
If you are reporting as a group, the Prevention of Information Blocking Attestation applies to all MIPS-eligible clinicians within the group. Therefore, if one MIPS-eligible clinician in the group fails to meet the requirements of the attestation, then the whole group would fail to meet the requirement.
Q: What actions are required?
A: If you want to earn a score for the advancing care information performance category, you have to act in good faith when you implement and use your CEHRT to exchange electronic health information. This includes working with technology developers and others who build your CEHRT to make sure the technology is correctly used, connected, and enabled to meet applicable standards and laws. You must also ensure that your organizational policies and workflows do not restrict the CEHRT’s functionality in any way. For example, if your CEHRT can give patients access to their electronic health information or exchange information with other MIPS-eligible clinicians, your practice must use these capabilities.
The Centers for Medicare & Medicaid Services recognizes that circumstances beyond a MIPS-eligible clinician’s control may limit the exchange or use of electronic health information. This is why the Prevention of Information Blocking Attestation focuses on (1) whether you act in good faith to exchange electronic health information and (2) your particular situation. This focus takes into account a MIPS-eligible clinician’s individual circumstances, such as
- practice or organization size,
- how much technology there is, and
- what the CEHRT can do.
However, the attestation does not
- assume how much clinicians know about technology or
- hold clinicians responsible for outcomes they cannot reasonably influence or control.
Read previous articles in “Advances in Skin & Wound Care” by Cathy Thomas Hess in the link.
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Cathy is Chief Clinical Officer for WoundExpert® and Vice President at Net Health, and in addition to being the MIPS Clinical Consultant for WoundExpert. She gained over 30 years of expertise in various acute care, long-term care, sub-acute care facilities, home-health agencies, and outpatient wound care department settings. Cathy is the author of Clinical Guide to Skin and Wound Care (also translated into Italian and Portuguese) – Eighth Edition published in September of 2018.