Measures Groups. They have been the dependable go-to PQRS reporting option for small practices across the country, not only saving time and effort, but becoming a life-saver for practices who cannot afford to implement a costly EHR.

The release of the 2017 Final Rule in late October verified that CMS has chosen to remove this reporting option for MIPS participants. With an estimated 6,361 practices successfully utilizing Measures Groups in the 2014 reporting year alone, the impact of retiring this mechanism will be felt nationwide.

CMS’ response to the concerns about removing Measures Groups is that they have introduced specialty measure sets to help providers select measures and that few providers use Measure Groups. What they don’t realize is that the greatest advantage of Measures Groups to small practices is not the selection of measures, but the sample size: just twenty patients for each measure.

With the reduced completeness criteria (50% of eligible patients) and 90-day performance period, the transition year of 2017, will make it easier for small practices to participate than was originally proposed. However, the performance period and completeness criteria are expected to increase up to a full year and 90% of all payer data.

CMS has shown in the past that they are listening to us, and have incorporated the comments and suggestions from those affected by the program. In an attempt to help CMS understand the impact of this loss, I have submitted a comment to CMS requesting them to reinstate Measures Groups as a reporting option. You can read my comment below. I want to reassure you, that even if there is no change to the Final Rule, we are here to help practices of any size, make a qualifying submission for the new Quality Payment Program.

Dr. Dan Mingle’s comments to CMS:

I reiterate my recommendation and request that you reinstate the Measures Groups reporting options under MIPS. The loss of the Measures Groups options creates a tremendous reporting burden on small practices. By taking away the Measures Groups options you are setting small practices up for failure and creating unreasonable pressure for them to consolidate to be able to keep up with reporting requirements.

In the final rule published in the Federal Register, Volume 81, No. 214, November 4, 2016, on Page 77008 you explain:

“Comment: Several commenters recommended that CMS reinstate measures group reporting as an option under MIPS.

“Response: We did not propose the measures group option under MIPS because, as commenters noted, very few clinicians utilized this option under PQRS. Under the MIPS, we substituted what we believe to be a more relevant selection of measures through specialty specific measure sets. Adopting this policy also enables a more complete picture of quality for specialty practices. We do not believe the specialty-specific measure set will pose an undue burden on small practices, and may make it easier for eligible clinicians, including those in small practices, to easily identify quality measures to report to MIPS. We will continue to assess this policy for enhancements in future rulemaking.”

The most recent data available from CMS on utilization of these methods comes from the 2014 PQRS Experience report. In that report, utilization by individual eligible providers is given in Figure 4 in the table, below. When you factor in effectiveness of the mechanism from Figure 6, Measures Groups performed extraordinarily well and put it on a par with effective utilization of individual registry measures and EHR submissions.

The more compelling perspective is to look at the utilization by practice rather than by eligible provider. Your best data on this is in table 3 but does not include a number for Measures Groups. The Practice utilization given in the table, above, comes from table 3 except for the count of practices using Measures Groups which we estimating from our experience combined with the data given in the 2014 experience report. From our experience, practices that depend on Measures Groups average in size about 5 providers per practice. If we divide the number of providers using Measures Groups by 5, we estimate utilization by practice at 6,361. This is three times as many practices as use all of the GPRO submission mechanisms combined.

Consider also, that the lowest participant rates are found in the smaller practices. As increased potential negative adjustments under MIPS drive more practices to participate, it is smaller practices that constitute the majority of the gap.

Again, looking to the 2014 Experience report for data, this time from the Table 5 in Appendix Tables we can derive the numbers in the following summation table. If the 27% participation rate of the smallest practices increases to equal the 2014 participation rate at 82% of the largest practices, and Measures Groups utilization rate remains the same, you will have nearly 110,000 providers in almost 24,000 practices using Measures Groups.

Small practices have been slower to adopt EHR than have been larger practices. The ONC in their Data Brief No. 28 in September 2015 estimated that 83% of physicians had adopted an EHR. But the implementation rates are lower in smaller practices. In the same report, only 64% of solo practices had implemented any kind of EHR.

An additional factor crippling small practices in our experience as a Qualified Registry Vendor is that most EHR systems do not have adequate data for more than the simplest quality reporting. Most small practices, even if they have an EHR, cannot produce quality of care reports directly from the EHR, nor can they afford the custom reporting required to do so. Small practices, 25 providers or less, rely heavily on manual chart abstraction to generate quality reports, whether they have a paper chart or an EHR. This problem is going to be accentuated with MIPS data completeness criteria changing to all payers and eventually 90% reporting rate requirements. It is not unusual for a primary care provider to have 1500 patients generating 5,000 visits per year. Some measures apply to nearly all patients and some to all visits. The data abstraction load will be prohibitive.

Considering the dependence of the nation on small practices to deliver healthcare (55% of the nation’s providers are in practices of 1-25 providers), and considering the lack of access to data of those practices, and the increased chart abstraction load that will be experienced as we move to a 90% reporting rate requirement on an all-payer performance analysis, and considering Medicare’s long-standing conclusion that a 20-patient sample is statistically significant, I reiterate my request that the Measures Groups submission mechanism be reinstated in the MIPS program.

Thank you,

Dan Mingle, MD MS
President and CEO
Mingle Health

Did you send a comment to CMS about the 2017 Final Rule? If so, I’d like to read it and I encourage you to post them in the comments below.

Watch our recorded webinar with Dr. Dan Mingle to learn what the 2017 Final Rule means to you and your organization.

The 2017 Final Rule: MIPS and the Quality Payment Program

Watch our recorded webinar to learn what you need to know to get started with the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Models (APMs) under the new Quality Payment Program.

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