Recently, America’s Physician Groups (APG) sent a letter to Liz Richter, Acting Administrator of the Centers for Medicare and Medicaid Services (CMS) regarding recent changes to the Medicare Shared Savings Program (MSSP) and Quality Payment Program (QPP). In the letter, APG notes that the changes will “have a significant impact particularly for physician practice ACOs,” and offered several recommendations with the intent to strengthen the programs and “the overall movement from volume to value.”
Extend CMS Web Interface Reporting
The first recommendation APG made was to extend the option for CMS Web Interface reporting until issues have been addressed. APG notes that CMS has proposed stopping the use of its Web Interface reporting mechanism despite the fact that it is “heavily preferred” by MSSP and Next Generation ACOs. APG further notes that the costs and burden of the shift in reporting mechanisms is substantial for physician practice ACOs and the bulk of that burden will likely fall on the practices themselves. Additionally, because data extraction and aggregation across multiple electronic medical records (EMRs) is more challenging (lack of access translates to integration difficulties), it is likely that new interfaces will need to be created and not all EMRs are able to accommodate that.
APG also believes that the new reporting mechanism is likely to measure EMR data entry and extraction rather than quality performance, if rushed through. Furthermore, the use of these reporting mechanisms could result in inaccurate evaluation of ACOs’ quality performance based on the total patient population instead of patients assigned to an ACO as the MSSP statute and prior regulations intend.
Set Shared Savings Eligibility Standards Using a Target, Published in Advance
APG also recommends that CMS set shared savings eligibility standards using a target that is established and published in advance. The group notes that CMS has stated its attempt to align MSSP quality standards with the MIPS quality performance category. This would establish a newly modified quality performance standard that would require ACOs to reach the 30th percentile across all MIPS quality performance category scores to qualify for shared savings, with that required performance level increasing to the 40th percentile in the 2023 performance year.
However, as APG notes, the 30th or 40th percentile could change dramatically from year to year based on the broader MIPS rules and how other MIPS reporters perform. This potential for significant change does not “provide sufficient transparency ahead of time for ACOs” and the all-or-nothing approach does not provide a sufficient incentive for providers to actually pursue quality performance and improvement.
Therefore, to help ACOs determine how they must perform to meet the standards, APG asks that CMS set a standard for shared savings eligibility, and establish and publish the target in advance.
Remove All-Payer Requirement
Third, APG recommends that CMS remove the all-payer requirement for measures reporting. APG believes there is a “lack of clarity and specificity” surrounding what all-payer reporting entails for ACOs, which “prevents providers from being able to adequately prepare for successful reporting.” APG is also concerned that the requirement may inadvertently discourage some providers from expanding access to higher need patients – including some Medicaid patients – out of concern for the impact it would have on their quality score.
APG notes that they “share CMS’ goal of improving quality of care for patients across all payer types, geographies, races, and socioeconomic status,” but “this change could unfairly disadvantage ACOs that serve higher need populations and may discourage ACOs from including practices with a payer mix that is unfavorable from a quality performance perspective, thereby furthering inequities rather than addressing them.”
Seek Additional Stakeholder Input
The last recommendation APG makes in the letter is that CMS seek additional stakeholder input on the recent changes to quality measures.