Accountable care organizations participating in the Medicare Shared Savings Program must always be prepared to adapt to changes in reporting requirements and methods. One big hurdle coming up is that by 2025, ACOs will be required to do quality reporting to CMS via electronic clinical quality measures (eCQMs).
During a recent podcast, Emily Levi, program manager at MaineHealth ACO, spoke about the significance of the changes coming down the pike and how her organization is preparing. “The major change is in how much we have to report and who has to report and how it happens,” she said.
Levi described what happens today: CMS gives MaineHealth ACO a sample of patients that it has to report on and the ACO looks at where those patients are attributed. The ACO manages that quality submission mainly by working with primary care providers. “What's going to change is that instead of the ACO manually going in to the EHRs and pulling the quality data, that data is going to have to be pulled electronically from the electronic health record, meaning our participants have to make sure they are meeting EHR requirements,” she said. “They have to also be making sure that they're documenting in a certain way so that data can be pulled directly from the EHR.” That means less opportunity, for example, to go in and pull information from the notes sections in the EHR, Levi explained. Information is going to have to be documented in a discrete field.
“This is very complex, and it's also a lot more reporting,” Levi added. “CMS is also looking at all providers having to report across all payers. Because this is so complicated, we're planning on working with a vendor to help support us, so we're finalizing that contract right now. We're hoping that we have one year to do an optional submission and work out the kinks of this program and look at where we have opportunities to improve our quality scores before we have to report for the 2025 program year. The ACO will still be working closely with the practices and really making sure that they know what they need to do for this and over the next year. It is a pretty major change, so we're excited to have a vendor on board — hopefully soon — to help support us with this transition.
In a recent interview with Healthcare IT News, Carol Ann Hudson is assistant vice president, quality and clinical operations, population health, at Tennessee-based Lifepoint Health, spoke about her organization’s experience as an early adopter of eCQMs. She said that early adopters were given concessions by CMS to test the system, making it easier to reach quality benchmarks. “These concessions have been financially beneficial for Lifepoint while also giving us time to expand reporting to all patients and continually improve our quality results,” Hudson said.
Hudson stressed that beyond data aggregation, the shift to eCQM is about education. “ACOs should work to ensure each practice is aware of the measures and how they will be held accountable. Each EHR is required to have a distinct way to capture measure data within the system and must be certified for the functionality,” she said.
Population health analytics solutions vendors are seeking to help ACOs meet the deadlines for reporting changes.
For instance, at the 2023 NAACOS Spring Conference, Innovaccer Inc. announced that it would support eCQM reporting in its quality management solution to help ACOs accelerate compliance with the mandate to migrate from manual chart to 100 percent electronic reporting, while also expanding quality reporting from small samples to 70 percent of the entire patient population.
As Innovaccer explains, under the new rules, the existing manual Web Interface for MSSP quality reporting will be retired in 2025. CMS will require quality reporting exclusively using electronic clinical quality measures (eCQM). Moreover, instead of receiving a small 248-patient sample from CMS to report on, ACOs will be required to report on 70 percent of patients that meet the measure criteria. These specifications also dictate that ACOs must report on all patients that meet the measure criteria regardless of the payer type or patient inclusion in the ACO program.
In addition, CMS is increasing eCQM reporting from four eCQMs (one mandatory and three self-selected) to six eCQMs (three mandatory and three self-selected) beginning with the CY 2024 reporting period for FY 2026 payment determination.
The MaineHealth ACO podcast also highlighted some opportunities and challenges the ACOs and other provider groups are facing.
MaineHealth’s MIPS score for the 2022 performance year was 98.23, which resulted in a payment adjustment of 7.17 percent that providers will see in 2024. “That is the highest payment adjustment that we have seen since participating in the program since back in 2017,” Levi said. She said that it appears most likely that non-ACOs, did not perform as well. And because it's a budget neutral program, CMS has more money to give to a smaller pool of participants this year. “We believe that's why our payment adjustment is 4.8 percent higher than it was in prior years. CMS also has made some changes to the program in the past few years. So that's why we think some non-ACOs might have had trouble meeting some of the quality benchmark changes and some of the quality reporting changes that we ACOs do not yet have to comply with.”
In the MSSP, MaineHealth did save CMS some money, but not enough to get a shared savings payment. “We saved the government $9.3 million and we need to save $11.5 million to take home a payment,” Levi said. “But in the grand scheme of things, we were actually pretty close — just $60 per beneficiary per year — short of getting a payment. It does look like there are some opportunities to close those gaps and get that payment in future years. The good thing is that the way this program works it that CMS first looks at cost and you need to meet that cost target first. If you meet the cost target CMS looks at your quality score, and you need to meet what CMS calls a quality gateway. Our quality score was good, and we did meet that quality gateway. So if we had hit that cost target, we would have earned payments this year."