In a letter to HHS Secretary Xavier Becerra, a dozen medical groups and healthcare organizations called upon the Biden administration to delay and make significant changes to the way accountable care organizations report and are measured on quality. Groups like the American Medical Association (AMA), the American Hospital Association (AHA), and America’s Physician Groups, among others, said they had “significant concerns” about the Medicare Shared Savings Program (MSSP) quality policies finalized at the very end of 2020. The groups cited concerns about rushed implementation, still unanswered questions on changes, and potential negative consequences to patient care. If changes are not made soon, ACOs and their participants will bear significant health information technology costs and upgrades to be able to collect and report data, the groups said in the letter.
Letter Recommendations
The letter lists six recommendations for HHS to consider. First, the letter asks: “Delay the mandatory reporting of eCQMs and MIPS CQMs for at least three years. ACOs support the move to electronic reporting given benefits of reduced manual chart abstractions and reporting, but they anticipate notable barriers which outweigh those benefits, including: 1) the lack of standardization across EHRs and 2) the administrative burdens and costs associated with the new reporting requirements.” This recommendation notes that ACOs have a significant number of vendor systems from which data would be collected. Almost 40 percent of ACOs reported they have more than 15 EHRs across their practices/participant TINs, making things complicated.
The second recommendation asks HHS to limit ACO reporting to ACO assigned beneficiaries only. It notes that data access concerns were one of the top three barriers identified by their survey respondents, which is directly relevant to the expansion to all-payer data. It argues that expansion to the broader population could provide a snapshot of care within a community, but it is likely not representative of the care provided by the ACO. A third recommendation asks HHS to lower the data completeness requirements beginning at 40 percent with a gradual increase to a maximum of 50 percent for those reporting eCQMs or MIPS CQMs or explore alternative approaches.
Recommendation four asks HHS to reassess the appropriateness of the measures included in the APP measure set and solicit additional input through the MAP prior to finalizing a complete set of patient-centered measures for reporting. Fifth, the groups want clarity regarding quality performance benchmarks in advance for all ACO reporting options. Finally, the sixth recommendation calls for retaining pay-for-reporting when measures are newly introduced or modified.