If you are managing a Medicare Shared Savings Program accountable care organization (MSSP ACO), you have heard the mandate from the Centers for Medicare & Medicaid Services (CMS) to move to eCQM/CQM reporting, replacing the Web Interface reporting. You may also be aware of the significant pushback that ACOs, collectively and independently, have provided to CMS. At this year’s fall National Association of ACOs (NAACOS) conference, the tenor changed to accepting the move, optional in 2022 through 2024, but required in 2025.
The 2023 Provider Fee Schedule Proposed Rule was released in July and there are changes that accountable care organizations (ACOs) need to be aware of. This blog will focus on the most important changes from a quality reporting perspective.
For ACOs participating in the Medicare Shared Savings Program (MSSP), CMS is implementing rules in 2021 and 2022 for quality reporting which include a sweeping change. This change will require a new reporting approach, in order to aggregate data from electronic health record systems used across an ACO for all patients seen by any provider, regardless of payer or participation in the ACO. In a recent survey, nearly 75% of the ACO respondents indicated concern with the challenge of these requirements. The Web Interface reporting is being sunset, and ACOs need to devote attention to determining their strategy for transitioning quality reporting. Success will require thoughtful planning and experienced system implementation.
As we move into 2021 and beyond, we see CMS putting some real teeth into the Merit-based Incentive Payment System (MIPS) program. This is the first year where we see more than two percent incentives possible. Exemptions and exclusions are narrowing. Participants in other value-based programs are being forced into MIPS reporting because of higher thresholds for exclusion and elimination of other reporting options.
The long-awaited CY 2021 Medicare Physician Fee Schedule Final Rule update is now here. Despite the disruptions of the Public Health Emergency COVID-19, participation in performance year 2019 was strong. Thus the 2021 Final Rule moved forward with finalizing a number of proposed changes, including a higher performance threshold for performance year 2021, anticipated changes in weight to the Quality and Cost performance categories of the Merit-based Incentive Payment System (MIPS), and the introduction of the APM Performance Pathway. Other expected initiatives, such as MIPS Value Pathways, the requirement for registries to build their own benchmarks for certain measures, and the sunsetting of the CMS Web Interface, have been pushed back to at least the 2022 performance year.