Recently, the Centers for Medicare & Medicaid Services (CMS) published the final Quality Measure Development Plan which is a “strategic framework for [Medicare] clinician quality measurement development to support the new Merit-based Incentive Payment System (MIPS) and advanced alternative payment models (APMs)” under the Medicare Access and CHIP Reauthorization Act (MACRA). The final plan incorporates stakeholder feedback the December 2015 draft plan.
MACRA
Section 102 of MACRA requires that the Secretary of Health and Human Services (HHS) develop and post on the CMS.gov website “a draft plan for the development of quality measures” by January 1, 2016, for application under certain applicable provisions related to the new Medicare Merit-based Incentive Payment System (MIPS) and to eligible Medicare alternative payment models (APMs). The law further requires the final plan to be posted on the CMS website by May 1, 2016.
The Plan
The plan aims to refine quality measures to identify measurement and performance gaps in clinical care, safety, care coordination, patient and caregiver experience, population health and prevention, and affordable care. It will promote and align quality measures and improve coordination with federal agencies to avoid replication of efforts. Additionally, it aims to coordinate with clinicians to make sure the quality measurement process is relevant to their practices, reduces administrative burdens, and also takes into account patients and families.
Role of CME
To advance the mission of improving health care outcomes, beneficiary experience of care, and population health while also reducing health care costs, the CMS Quality Strategy identifies four foundational principles that guide actions toward the achievement of these goals:
- Eliminate racial and ethnic disparities to achieve an equitable health care system.
- Strengthen infrastructure and data systems essential to a robust health care system.
- Enable local innovations to allow each community to meet its needs.
- Foster learning organizations to promote learning and education as key parts of quality programs and initiatives.
The final foundational principle promotes “learning and education” as a critical aspect of the agency’s goal of promoting quality. This is especially important as the Secretary of HHS further defines the new clinical practice improvement activities. Continuing medical education (CME) has long been recognized as a means by which physicians demonstrate engagement in continued professional development. This encourages physicians to develop and maintain the knowledge, skills, and practice performance that leads to optimal patient outcomes. Patients will continue to need health care professionals that engage in lifelong learning, assessment, and improvement in practice, so it is important these activities be recognized and rewarded in value-based payment programs promulgated by CMS and private payers.
Comments
According to CMS, comments it received on the draft plan include:
- Many commenters expressed support for the strategic approach of the Quality Measure Development Plan.
- Responses favored CMS’ intent to engage clinicians, medical societies, and other stakeholders more broadly in measure identification, selection, and development processes for MIPS and APMs.
- Professional associations representing diverse clinical practice areas identified current measurement gaps and proposed priorities for measure development that are directly applicable to their specialties.
- Consumer advocates urged CMS to partner with patients, families, and caregivers and recommended a model for engaging them in measure development.
- Many commenters approved of the approach envisioned by the National Testing Collaborative and the National Quality Forum (NQF) Incubator to promote early engagement of stakeholders in measure development and testing.
- Both organizations and individuals contributed insights into the integral roles of their clinical professions or practices in the U.S. health care delivery system.
This comes as CMS released the long-awaited proposed MACRA rule which is open for comment until June 27. This Measure Development Plan is important because the new MIPS system will determine how many physicians are paid under Medicare, especially since so few “Advanced APMs” will immediately exist. It is also likely the measures will be adopted in some form by private health insurers as well. We are working on a comprehensive analysis of the MACRA proposed rule but at 900+ pages it is taking us longer than we anticipated.