Tuesday, December 6, 2016

New Era of CQMs, Part I: Quality Measures in The Age of MIPS

The first performance year for the CMS Merit-based Incentive Payment System (MIPS) begins on January 1 of next year, yet much of the healthcare world is still in the dark about large portions of the program. Or even unaware of its existence entirely.

Perhaps one of the most misunderstood aspects of the program: MIPS does not apply to Medicaid Meaningful Use or eligible hospital Meaningful Use (MU) programs.

With MIPS beginning in earnest and ramping up over the next few years, we wanted to provide a series of plain-language posts and address how it will affect your use of clinical quality measures.

Our goal as the program unfolds is to grow our CQMsolution software to support as many measures as possible.

MACRA sets up a new system of quality-based reimbursement for clinicians called the Quality Payment Program.  Within this new model, there are two pathways to select:
  • The Merit-based Incentive Payment System (MIPS)
  • Advanced Alternative Payment Models (APMs)
For this post, we will focus on quality assessment within the context of MIPS. Multiple quality reporting programs are folded into MIPS:
  • Physician Quality Reporting System (PQRS)
  • Value-Based Payment Modifier (VBM)
  • Medicare Electronic Health Records (EHR) Incentive Program (ie, Meaningful Use)
As with the current PQRS program, multiple clinicians can participate in MIPS as an individual or a group.

Payment adjustment

In determining the payment adjustment based on MIPS, clinicians will received a composite score, weighting four different categories of performance:
  • Quality
  • Resource user
  • Clinical practice improvement activities
  • Advancing care information 

Quality Measures under MIPS
Quality receives the highest weight under MIPS and to determine quality score. The program has taken PQRS and the value-based modifier, mashed them up and provided a menu of quality measures that will determine reimbursement.

MIPS-eligible clinicians and groups can select their measures from either the list of all
MIPS measures or a subset of specialty-specific measure as identified by CMS. Unlike the current requirements under PQRS, clinicians will not be required to report a "cross-cutting measure." The program has been positioned to allow clinicians to select measures that are the most relevant to their practice.

In the transition from the current state of quality reporting (PQRS/VBM/MU) to MIPS, there are a few other key points to bear in mind:
  • Registry, EHR and QCDR reporting measures currently require 9 measures across three quality domains, but thew new requirement is 6 measures
  • Measures can now have any combination of NQF quality domains, though the 6 selected must include an outcome measure (as opposed to strictly process, for example)
  • MAV process changed (more on this in future posts)
  • PQRS registry measures group method is eliminated
  • Registry and QCDR reporting requires meeting a "data completeness" standard: 50% of patients in the denominator
There are more complexities to explore - and changes and clarifications in the coming months, as always. We look forward to staying on top of these and simplifying the process for each of our clients.