As a clinician in a Shared Savings Program ACO, what are my reporting requirements?

Quality Performance Category: Your ACO is required by the Shared Savings Program to report quality measures through the CMS Web Interface. The quality data reported to the CMS Web Interface by the ACO will be used to score the MIPS Quality performance category and the score will apply to each MIPS clinician in the ACO.

Improvement Activities and Cost Categories: As a MIPS clinician in the Shared Savings Program ACO you won’t need to report any data for the MIPS Improvement Activities performance category because you will automatically receive full points for this category. In addition, MIPS clinicians in a Shared Savings Program ACO will not be assessed on the MIPS Cost performance category.

Advancing Care Information Category: All ACO participant TINs in a Shared Savings Program ACO, including ACO participant TINs that are in a Track 2 or 3 ACO, are responsible for submitting data on the Advancing Care Information performance category apart from the ACO as specified by MIPS. This information is necessary for the Shared Savings Program to measure the level of CEHRT use among clinicians participating in the ACO.

APM Scoring Standard: The Shared Savings Program is a MIPS APM, and all MIPS clinicians in Shared Savings Program ACOs will receive special scoring for MIPS under the APM scoring standard. Consequently, all MIPS clinicians in your ACO will receive the same MIPS final score.

What if my ACO does not successfully report quality measures through the CMS Web Interface? While unlikely, since most ACOs successfully report quality measures through the CMS Web Interface, if you believe your ACO won’t report what it needs to under the Shared Savings Program, your ACO 4 Quality Payment Program Fact Sheet participant TIN can submit quality data for the performance year under any of the MIPS standard reporting options. If the ACO doesn’t meet its reporting requirements, we’ll look for and use any quality data for the performance year that your ACO participant TIN sent in apart from the ACO to score your quality domain under MIPS. Your ACO participant TIN will still receive full points for the MIPS Improvement Activity performance category and it will not be assessed on the MIPS Cost performance category. Your ACO participant TIN will still need to report for the Advancing Care Information category according to the MIPS requirements for this category. Instead of being scored at the ACO level, the MIPS clinicians under each ACO participant TIN will receive their own MIPS final score.

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