Based on your responses to the questions in the ACO Data Survey, it's likely that MIPS CQMs are your
organization's best option for the APM Performance Pathway (APP) transition.
What is a MIPS CQM?
A MIPS CQM is a Clinical Quality Measure designed for use in CMS’s Merit-Based Incentive Payment System (MIPS).
Specifications for MIPS CQMs are typically provided in natural language. The qualified registries that use and submit these measures tend to interpret these specifications into processes in their software.
CMS sets the requirements for qualified registries, and CMS does the initial qualification and maintenance of that qualification.
Data for MIPS CQMs can come from any valid source, an EHR, an electronic registry, or even a paper chart. The data can be manually or electronically abstracted – but it must come from a valid data source.
Our friendly team is standing by to introduce you to our solutions and answer your questions.
Why are MIPS CQMs the best option for your organization?
Based on your responses to the ACO Data Survey, you’ll likely run into roadblocks to APP reporting via eCQMs. Those potential road blocks could be:
Your ACO’s patient population may be too large for sustainable data aggregation and analysis
Your ACO’s member practices may be on different EHR systems, or different instances of the same EHR system, or on non-ONC Certified EHR systems
If your ACO doesn’t already have a centralized data hub in place (or if you aren’t currently in the process of building a data hub) the investment of time and money into your data aggregation project could be immense and burdensome
If your ACO doesn’t have dedicated support staff to aggregate, normalize, monitor, and analyze your data, you may find the overall project unmanageable as you add member practices and attempt to meet CMS reporting deadlines
MIPS CQMs offer a much more scalable, sustainable, and affordable solution to the APP reporting requirements.
Your ACO likely consists of multiple independent practices, and there’s a good chance these practices have different EHR systems. Even if two different practices use the same EHR system, they could still be on different instances of that EHR system – which creates another problem in the eCQM reporting process. Aggregating and de-duplicating data from multiple EHRs isn’t simple, and the cost and time investment required can be too burdensome for many ACOs.
On the other hand, registries have been taking data from multiple health IT systems since PQRS began in 2007. Working with a Quality Registry to satisfy the APP requirements with MIPS CQMs can reduce maintenance, lower costs, and increase flexibility for your ACO.
Will eCQMs be your only option after 2025?
It’s a common misperception that Medicare will eliminate the MIPS CQM submission option for the APP after 2025.
This misperception likely comes from the concurrence of messaging about the rules and concrete plans for the APM Performance Pathway (APP) and the simultaneous but unrelated introduction of the concept of Digital Quality Measures.
The Final Rule for 2022 for the Quality Payment Program was a big year for the APP. Medicare slowed the transition to the APP and memorialized its plans into rules. By 2025, all MSSP ACOs must stop using the Web Interface and participate in the APP using eCQMs or MIPS CQMs.
In that same Final Rule for 2022, Medicare introduced the relatively unrelated concept of Digital Quality Measures.
Digital Quality Measures were introduced by requesting comments on the provocative statement:
“We aim to move fully to digital quality measurement in CMS quality reporting and value-based purchasing programs by 2025.”
“(iii) An ACO will not meet the quality performance standard or the alternative quality performance standard if:
“(A) …
“(B) For performance year 2025 and subsequent years, the ACO does not report any of the three eCQMs/MIPS CQMs and does not administer a CAHPS for MIPS survey under the APP.”
This rule confirms that MIPS CQMs and eCQMs will continue to be available after the sunset of the Web Interface option after the 2024 Performance Year.
There is no date set in Medicare rules after which MIPS CQMs will not apply to APP quality reporting.
Get Started with MIPS CQMs
The APP transition doesn’t have to be expensive, time-consuming, or scary. With our help, ACOs like yours are gaining a previously unattainable view of their data, no matter the number of patients, providers, locations, or EHRs. Our platform allows you to diagnose challenges at any level, and your dedicated Mingle Health consultant will help you monitor your performance to increase your chances of earning shared savings.
Better yet, by not locking your data into one technology platform, our solution prepares your organization for whatever comes next, whether that’s FHIR, dQMs, or a new set of CMS requirements.
And with Mingle Health, your APP reporting workflow will be operational within 90 days.
