Accountable care organizations (ACOs) face unique burdens to comply with CMS’s new quality reporting requirements as summarized in this 2021 MedCity News article. Challenges are particularly acute for ACOs that delayed conversion from CMS’s Web Interface to the new electronic clinical quality measures (eCQM) quality reporting. Many ACOs have made the change. But many have not.
With only six months remaining, now is the time for all ACOs participating in the Medicare Shared Savings Program (MSSP) to solidify their eCQM reporting capabilities. ACOs must gather data from all their EHRs and across all patients regardless of payer to comply with eCQM.
This article provides clear guidance for MSSP ACOs that have yet to meet the new quality reporting requirements.
Devil is in the details
The transition to eCQM quality reporting comes in the form of the APM Performance Pathway. This is the latest CMS reporting method tailored for MIPS Alternative Payment Models (APMs) and ACOs, effectively replacing the CMS Web Interface. ACOs must report the three eCQM/MIPS clinical quality measures during 2025 and all subsequent performance years.
While the number of quality measures for reporting is lower (three versus ten), the volume of Medicare patients is much greater. This makes interoperability across EHRs an essential requirement for all new ACO quality reporting. The three measures are diabetes, depression screening, and hypertension.
The volume increase is massive and data accuracy is imperative to secure future shared savings revenue. If your ACO delayed the move from Web Interface to eCQM, here are the essential steps to take now.
Determine which reporting method you will use
There are three reporting choices to consider and ACOs need to determine which path is best for them: eCQM, MIPS CQM, or Medicare CQM. Data can be acquired through a direct EHR connection, or flat file data uploads, such as QRDA-1s. ACOs can choose between using an CQM partner to pull EHR data from disparate systems, aggregate it, and de-duplicate their patients, or use the QRDA-1 for push data uploads.
The decision hinges on factors such as data accuracy, timeliness, cost-effectiveness, and the ACO’s specific reporting needs.
Evaluate data sources and quality
CMS published an infographic in 2022 to outline all the major obstacles ACOs will face in shifting to eCQM reporting. EHRs and data aggregation are included in half of these obstacles. Certainly, the aggregation and normalization of data from multiple and diverse EHRs is crucial for successful quality reporting via eCQMs.
Choosing eCQM reporting means that ACOs must be able to extract quality patient data from each participating practice’s certified EHRs. Manual review of records to gather quality measure data is no longer feasible given the sheer volume of information required. CMS recommends ACOs work with their vendors to navigate these obstacles.
The first step is for ACOs to ask vendors important questions related to system readiness, data quality, and interoperability. Here are five questions to discuss immediately with all EHR vendors across the ACO.
Is my version of the EHR CEHRT certified?
What fields need to be used to capture eCQM/CQM data?
Can information be pulled from both structured and unstructured documents?
What options are available to collect data?
Which workflows need to be changed?
Organizations such as the National Committee for Quality Assurance (NCQA) have established new data aggregator validation programs to help ensure data quality in eCQM reporting. For example, NCQA’s Data Aggregator Validation (DAV) program evaluates the management and exchange of health data through a rigorous, proven process.
DAV designation reflects an additional layer of trusted accuracy for aggregated clinical data within eCQM and other quality programs. Data validation is important for ACOs to consider as they evaluate vendor partners for eCQM / CQM conversion.
Layering dashboards on top of high-quality aggregated data is the next step for ACOs to accomplish over the next six months.
Build dashboards for visibility into performance
ACOs that have already converted to eCQMs can measure practice performance for each quality measure across all patients. This type of data-first strategy also achieves a more holistic approach to quality monitoring and performance.
Dashboards help ACOs make more informed decisions, create transparency and accountability across participating practices, and enable greater flexibility for the organization to respond to change. This type of automated insight also helps ACOs identify and close critical care gaps across their patient populations.
Get physicians on board with the change
Change is never easy, but necessary to make progress. This adage has never been more relevant for MSSP ACOs. Getting physicians engaged with the transition from Web Interface to eCQM reporting is a high hurdle to cross. Success requires mutual trust and established relationships.
Specific steps for ACOs should include aligning physicians with the evolving requirements, optimizing clinical workflows, training and education, and ongoing feedback for continuous improvement.
Begin with the end in mind
The goal of ACOs is always to maximize MSSP performance by improving care quality. Shared savings incentives increase when quality improves, and eCQM reporting is now a key requirement to achieve these goals. Benefits include timely insights into quality performance, more accurate clinical data, and the opportunity to earn higher levels of shared savings revenue over time.
The good news is that many ACOs have already made the transition to eCQM reporting. Proven best practices are now available. Savvy ACOs will capitalize on efforts to optimize broader quality initiatives under value-based payment over time.
I advise all ACOs beginning the eCQM journey to take advantage of available industry resources, evaluate proven options, and get started as soon as possible. Delays in 2024 will put at risk revenues for 2025, and potentially all future performance reporting years.
Source: skynesher, Getty Images
James Pelletier serves as the National Director of Provider Quality at MRO, a clinical data exchange company and market leader in clinical data aggregation for eCQM reporting and Quality Payment Programs. With more than twenty years of healthcare technology expertise, James specializes in understanding provider challenges and helping them succeed in complying with the latest regulations in a risk-based world.
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