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Changes Ahead for ACO Reporting

Posted on November 30, 2020
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Accountable Care Organizations (ACOs) participating in the Medicare Shared Savings Program could have new reporting requirements beginning in 2023 and 2024. The Centers for Medicare and Medicaid Services (CMS) has proposed a three-year transition period to change the data that these organizations must report and how the data gets submitted. The proposed changes are intended to reduce reporting burdens and improve patient outcomes. The provisions would allow ACOs to partner with CMS Qualified Registries like MDinteractive to meet their data reporting needs. 

Elimination of the CMS Web Interface in 2024

CMS has proposed to end the CMS Web Interface reporting option for Medicare Shared Savings Program (MSSP) ACOs in 2024. ACOs would have a transition period for the 2021-2023 performance years before having to report all three eCQM/CQM MIPS measures established under the new Alternative Payment Model (APM) Performance Pathway

CMS is proposing the following transition period for MSSP ACOs:

  • 2021-2022 - ACOs would either report the 10 CMS Web Interface measures or the three all-payer eCQMs/MIPS CQMs. Under the APP, all ACOs would administer the CAHPS for MIPS Survey and be scored on two administrative claims-based measures (calculated by CMS).
  • 2023 - ACOs would either report the 10 CMS Web Interface measures and at least one all-payer eCQM/MIPS CQM or the three all-payer eCQMs/MIPS CQMs. Under the APP, all ACOs would continue to administer the CAHPS for MIPS Survey and be scored on two administrative claims-based measures (calculated by CMS).
  • 2024The CMS Web Interface would sunset. ACOs would have to report on all three eCQMs/MIPS CQMs and field the CAHPS for MIPS Survey. CMS would calculate two measures using administrative claims data, and all 6 measures would be included in calculating the ACO’s quality performance score.

APP Quality Measure Set

CMS is adopting a smaller measure set as part of the APP as highlighted in the table below.

*2021 - 2023 Only:  ACOs could choose to continue reporting Quality measures via the CMS Web Interface. 

Measure #Measure TitleCollection TypeSubmitter Type
Quality ID#: 321CAHPS for MIPSCAHPS for MIPS SurveyThird-Party Intermediary 
Quality ID#: 479 Hospital-Wide, 30-day, All-Cause Unplanned Readmission (HWR) Rate for MIPS Eligible Clinician GroupsAdministrative ClaimsN/A
Quality ID#: 480Risk Standardized, All-Cause Unplanned Admissions for Multiple Chronic Conditions for ACOsAdministrative ClaimsN/A
Quality ID#: 001Diabetes: Hemoglobin A1c (HbA1c) Poor ControleCQM/MIPS CQM/CMS Web Interface* APM Entity/Third Party Intermediary 
Quality ID#: 134Preventive Care and Screening: Screening for Depression and Follow-up PlaneCQM/MIPS CQM/CMS Web Interface* APM Entity/Third Party Intermediary
Quality ID#: 236 Controlling High Blood PressureeCQM/MIPS CQM/CMS Web Interface* APM Entity/Third Party Intermediary 
Quality ID#: 318Falls: Screening for Future Fall Risk CMS Web Interface*APM Entity/Third Party Intermediary
Quality ID#: 110Preventive Care and Screening: Influenza Immunization CMS Web Interface*APM Entity/Third Party Intermediary
Quality ID#: 226Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention CMS Web Interface*APM Entity/Third Party Intermediary 
Quality ID#: 113Colorectal Cancer Screening CMS Web Interface*APM Entity/Third Party Intermediary 
Quality ID#: 112Breast Cancer ScreeningCMS Web Interface*APM Entity/Third Party Intermediary 
Quality ID#: 438Statin Therapy for the Prevention and Treatment of Cardiovascular Disease CMS Web Interface*APM Entity/Third Party Intermediary
Quality ID#: 370Depression Remission at Twelve MonthsCMS Web Interface*APM Entity/Third Party Intermediary 

Quality Performance Standard

ACOs would also have to meet a new quality performance standard to qualify to share in savings or avoid owing maximum shared losses. CMS plans to gradually phase in the increase in the level of quality performance as follows:

  • 2022 - If an ACO reports either:
    • The 10 CMS Web Interface measures and achieves a quality performance score equal to or higher than the 30th percentile across all MIPS Quality performance category scores, the ACO would meet the quality performance standard used to determine shared savings and losses; or
    • The three eCQM/MIPS CQM measures (meeting data completeness and case minimum requirements) and achieves a quality performance score equal to the 30th percentile benchmark on one measure in the APP measure set, the ACO would meet the quality performance standard used to determine shared savings and losses.
  • 2023 - If an ACO reports either:
    • The 10 CMS Web Interface measures and at least one eCQM/MIPS CQM measure and achieves a quality performance score equal to or higher than the 30th percentile across all MIPS Quality performance category scores, the ACO would meet the quality performance standard used to determine shared savings and losses; or
    • The three eCQMs/MIPS CQM measures (meeting data completeness and case minimum requirements) and achieves a quality performance score equal to the 30th percentile benchmark on one measure in the APP measure set, the ACO would meet the quality performance standard used to determine shared savings and losses. 
    • Note:  If an ACO chooses to report the 10 CMS Web Interface measures and does not report at least one eCQM/MIPS CQM, then the ACO would not meet the quality performance standard.
  • 2024 - The threshold for the quality performance standard would increase to the 40th percentile MIPS Quality performance category score. 
    • Note: If an ACO does not report any of the 3 eCQM/MIPS CQM measures and does not administer a CAHPS for MIPS survey under the APP, the ACO would not meet the quality performance standard.

Benefits of Using a Qualified Registry

Collaborating with a Qualified Registry will make sense for many ACOs. Qualified Registries like MDinteractive can help ACOs comply with the data reporting requirements while supporting their ability to make informed decisions on how best to improve the quality of care for Medicare patients within their organizations.

Combining Data from Multiple Sources.

ACOs may face data collection and reporting challenges if they have multiple Tax Identification Numbers (TINs), or are currently using multiple EHR platforms or billing systems. We have extensive experience aggregating quality data before it gets submitted to CMS. MDinteractive can aggregate data for each of the three quality measures from multiple sources and in various formats, including different EHR files (QRDA, CSV, Excel, or PDF), billing files (MDinteractive standard billing templates, 837 claims files, and unique billing files), excel templates and custom files. 

Know Your Performance.

It is important that ACOs monitor their performance throughout the year so they can make any necessary quality improvements to maximize their scores and incentive payments. MDinteractive’s software provides tools that allow ACOs to evaluate and monitor their performance at the ACO, TIN, and individual clinician National Provider Identifier (NPI) level.

Reliable Data Reporting.

MDinteractive has over 20 years of quality reporting experience with healthcare clinicians of all sizes and in all practice settings in every state. We have been a CMS Qualified Registry since 2010. Our customers include large academic medical centers, hospitals, billing companies, multi-specialty clinician groups, small groups, and solo practitioners. 

Knowledgeable and Experienced Team.

At MDinteractive, our seasoned team helps ACOs navigate through the reporting process from beginning to end and offers advice on how to maximize their reimbursement and avoid sharing losses.

Key Takeaways

ACOs should begin evaluating their quality reporting strategy in light of the new changes to the quality metrics they will have to report and the elimination of the CMS Web Interface in 2024.  Partnering with an experienced Qualified Registry like MDinteractive can help make it a smooth transition.  We can help ACOs successfully comply with their quality reporting requirements and provide tools and support to help them increase their Medicare payments through higher earned shared savings.
 

MACRA MIPS ACO Reporting APM Performance Pathway CMS Web Interface

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