To report to MIPS for a performance period ( 414.1320(i)) for the PI performance category, a MIPS eligible clinician must use Certified EHR Technology (CEHRT), as defined at paragraph (2) under CEHRT at 414.1305, report on the objectives and associated measures as specified by CMS, and submit required attestations as specified in 414.1375(b)(3) ( 414.1375(b))
Trouble is, we all know that kids are going to experiment
The CY 2010 final rule adopted the proposal, with minor adjustments based on public comments, and explained that these minor adjustments were in part due to non-response bias that results when the characteristics of survey respondents differ in meaningful ways, such as in the mix of practices sizes, from the general population (74 FR 61749 through 61750)
CMS also proposes to limit participation in the prepaid shared savings payment option to ACOs that have fully repaid all shared losses they may owe and any advance investment payments they may have received in a prior agreement period, and to ACOs that participate in a two-sided risk track (Levels C-E of the BASIC track or the ENHANCED track), as these tracks require a repayment mechanism in accordance with 425.204(f), which could be used to recoup prepaid shared savings
To understand what that delay is worth, you need a realistic picture of the biological timeline