CMS is looking to modernize the ACO reporting process by mandating the use of electronic clinical quality measures (eCQMs). However, accountable care organizations (ACOs) are concerned that the lack of healthcare interoperability will make electronic ACO reporting near impossible.
“CMS must avoid making eCQMs mandatory until standard data fields exist across EHRs, and true interoperability is achieved,” the National Association of ACOs (NAACOS) said in a Sept. 13th letter to CMS Administrator Chiquita Brooks-LaSure.
CMS had previously mandated ACOs report quality using eCQMs starting next year. The agency later backtracked the mandate, instead proposing to phase in electronic ACO reporting over the next couple of years. If the 2022 Physician Fee Schedule proposed rule is finalized as is, then electronic ACO reporting using eCQMs would be mandatory starting in 2024.
CMS also proposed in the rule to increase the quality data completeness standard from 70 to 80 percent by 2023 and increase the quality performance standard in Medicare’s flagship ACO program, the Medicare Shared Savings Program, to the 40th percentile by 2024.
“Aggregating eCQM data at the ACO level is not appropriate and, in some cases, not technically feasible at this time,” NAACOS countered in the letter to the head of CMS.
An ACO is a group of physicians, hospitals, and other healthcare providers who choose to work together to deliver coordinated, high-quality care to patients. Being made of so many different providers, however, presents many technical challenges. For example, providers may be part of the same ACO but operate different EHR systems, NAACOS explained.
In a recent survey, the Association representing 370 ACOs nationwide found that nearly half of ACO include practices using 11 or more EHR systems. Additionally, the biggest obstacle to reporting eCQMs was lack EHR standardization, the survey found.
NAACOS urged CMS to work with ACOs and EHR vendors to create solutions to data aggregation challenges, which make electronic ACO reporting difficult.
“[U]ntil these solutions are widely available, electronic clinical quality measures (eCQMs) should not be mandated for ACOs,” the letter stated.
ACOs will also struggle with data completeness standards, if they can achieve them at all, since CMS would make the organizations responsible for de-duplicating patient data when submitting eCQMs, the association added.
Instead, NAACOS advised CMS to revise its proposal to make electronic ACO reporting using eCQMs optional.
“As ACOs and EHR vendors continue to prepare for this transition, we urge CMS to provide ACOs with at a minimum one additional year beyond what is proposed for a full transition to mandated eCQM reporting, permitting use of the Web Interface reporting mechanism through 2025, and removing the requirement to report one eCQM prior to full implementation,” the association added.
Additionally, NAACOS recommended that CMS avoid its broader strategy of aligning ACO reporting with the processes in the Merit-Based Incentive Payment System (MIPS), a large-scale value-based reimbursement model that rewards Medicare physicians for delivering quality, cost-effective care.
CMS intends to align quality reporting across the Medicare Shared Savings Program and MIPS, which includes the transition to eCQMs. The move is meant to harmonize quality reporting for value-based providers.
However, ACOs are worried that MIPS, which was designed to tie fee-for-service payments to quality, does not align with the ACO model. In an ACO, providers must develop population health management capabilities and are held more accountable for quality outcomes and costs of care compared to MIPS providers.
“While CMS has a statutory requirement to increase the quality standard for ACOs over time, we do not believe marrying the ACO quality assessments with a FFS-focused quality assessment structure meets the intent of that statutory requirement,” NACCOS explained in the letter. “Over 40 [percent] of MSSP ACOs are participating in Advanced APMs, not MIPS and that number will grow over time, therefore tying ACO quality reporting to MIPS is not appropriate.”
In the letter, NAACOS also advised CMS to:
Change new Shared Savings Program quality performance standards
Abandon the all-payer requirement for ACOs reporting eCQMs
Bolster education and guidance for a “successful transition” to electronic ACO reporting and new Alternative Payment Model Performance Pathways reporting
Fix the “rural glitch” by removing ACO-assigned beneficiaries from the regional reference population
The final Medicare Physician Fee Schedule rule for 2022 is forthcoming. CMS has not said when it will be released though.