In our Monthly MACRA Blueprint, we cite the principle that you can't optimize MACRA at year end. True performance improvement requires regular measurement, analysis, and communication. A continuous feedback loop gives providers the chance to see the results of their actions. Further, an explicit tie between Quality Scores and reimbursement solidifies executive engagement, to reinforce the benefits of provider-level process improvement.
But ACOs have a different situation with CQMs. They are required to follow a process defined by the CMS Web-Based submission method.
Under the CMS Web-Based submission method:
- ACO Measures have different IDs from "regular MIPS" measures;
- The ACO measure population is limited to the first 248 Medicare Beneficiaries, encountered at each TIN each year, while MIPS Measures are based on all patients across all payers.
- CMS provides data to the ACO on which beneficiaries are covered, and pre-calculates their scores based on claims history. This happens late in the year.
- ACO CQM scores are enhanced through a manual abstraction process that involves manual entry of supplimental data from charts. This is necessary because not all data required for CQMS is included in the claims data source.
- Data is aggregated at the ACO level, so physician-level feedback is only relevant in a generalized way.
So it stands to reason that ACOs cannot use monthly feedback loops to optimize their CQM scores, using CMS Web-Based tools. But we believe that Certified EHR Technology (CEHRT) can support a proxy process that will enhance ACO CQMs. Even if the proxy produces scores are not identical to the CMS Web-Based method, CEHRT-based CQMS do support monthly feedback looks. Here's how.
ACO Measures have different IDs - but - Of the 23 Quality measures ACOs will submit in 2019, only 11 matter for MIPS. Each of those 11 measures has an analogous MIPS-based measure, with the same rules for calculating performance scores.
- CMS provides data to the ACO late in the year - but - CEHRT contains the same data, managed in realtime. CEHRT measures can be generated any time.
- The ACO measure population is limited - but - the underlying CQM processes are identical regardless of patient and payer populations.
- ACO CQM scores are enhanced through a manual abstraction process - but - CEHRT measures tend to contain the information that claims sources do not contain, so the CEHRT measures are much more nearly complete than the claims-based sources used by the CMS Web-based method.
- Data is aggregated at the ACO level - but - CEHRT data is available at the individual provider level.
The biggest difference between ACO CQMs and MIPS / CEHRT based CQMS lies in the patient population. Under CMS Web-Based methods, the patient population (CQM denominator) consists of the first couple hundred Medicare beneficiaries seen by each TIN, each year. Those beneficiaries are "followed" by each CQM all year long.
The corresponding CEHRT-based measures follow all patients, for all payer types for each provider. Since physicians do not significantly modify their processes significantly between payers, the CEHRT-based CQMs will be an excellent proxy for modelling performance against the vey same standards measured by ACO CQMs. (Even CMS argues that a broader demographic, over longer time frames, result in more accurate measurement of the processes underlying CQMs).
So, here's the bottom line.
ACOs can use CEHRT from each member TIN to easily generate the same CQMs used in the CMS Web-Based tools. Those CEHRT CQMs measure the very same processes as do the corresponding ACO measures, and so so more completely, for each individual physician. By measuring monthly, and individually, a Monthly MACRA program for ACOs can absolutely measure CQM performance. At year-end, when ACOs follow thier CMS Web-Based methods, the numerators and denominator won't be the same as those used throughout the year ... but the resulting performance scores will reflect the improvement measured throughout the year.
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MACRA Monitor is an subscription-based product from C3 Partners that combines a MACRA database with dedicated Concierge service for ACOs and other complex organizations