In the CMS 2021 Final Rule for the Physician Fee Schedule, CMS announced the new APM Performance Pathway (APP) and the end of Web Interface after the 2021 performance year.
CMS’s overall goals are to improve quality and reduce cost in the transition to value-based care. Here at Mingle Health, we continue to observe CMS consolidating and working to align components of quality and compliance programs. This is the case with the APP and 2021 changes; The APP reduces the number of quality measures for ACOs and aligns the reporting methodology with MIPS. Rather than report 10 measures, the APP requires only 3. We anticipate the most challenging change for ACOs and other groups accustomed to Web Interface will be the new all payer, all patient data completeness requirements. We’ll dive into this in a moment.
What is the APM Performance Pathway (APP)?
In addition to sunsetting Web Interface, CMS has introduced the new APM Performance Pathway (APP). The pathway is designed to streamline and simplify reporting requirements, especially for ACOs participating in Medicare Shared Savings Program (MSSP). The APP includes three quality measures, two CMS administrative claims measures, and CAHPS. Unlike Web Interface, the quality measures include all encounters across all patients and all payers. This aligns the quality measurement process more closely with MIPS.
The APP significantly changes how MIPS APMs and their members participate in the QPP. Before, CMS data from the MIPS APM was used for MIPS scoring for the entity and its members. Now, the APP can be reported at the individual, group, and APM entity levels. Individual and Group entities within a MIPS APM may can now participate via the APP or traditional MIPS and CMS will give them whichever score is higher.
|Program Component||Web Interface||APM Performance Pathway|
|Encounters||248 patients||All patients
The changes will have a major impact on ACO leaders and managers, and administrators working in any practice that is part of an ACO. These leaders are going to have a lot of pressure to demonstrate strong performance and make measurable improvements, both to quality and cost of care, year over year.
Clinicians are going to feel this pressure to perform in a personal way, because whether or not it’s a care issue or simply a documentation, process, or workflow issue, if you have low performance on a measure for a clinician, that feels like a direct reflection of how good of a clinician and care team they are.
Quality and population health management teams are also going to be in this mix. Leaders are looking to them for answers about why performance is, where it is, and what can be done to see continued improvement. The APP quality measurement methodology will enable ACOs and administrators to drill-down to the location, practice, provider, and even patient-level to understand why measure performance is the way it is.
A new quality measurement and reporting process will impact the entire organization, especially larger ones. For many organizations there’s multiple EHR, practice management, and billing technologies in place. Additional factors include change management, governance structures, and the politics of the organization. Everyone’s holding you accountable for their performance, and at the end of the day, only results matter.
We recommend that you get prepared, and you understand how this is going to impact both your scoring and your process. Use 2021 to prepare for the transition so you are ready in 2022, when you’ll no longer be able to utilize web interface.
APP Reporting Details
Let’s walk through the APP measures and how they compare to Web Interface. The APP includes three self-reported quality measures, two CMS administrative claims measures, and CAHPS. The quality measures can be reported from your EHR (eCQM) or a Qualified Registry (CQM).
|Measure||Web Interface||APP||Submitter Type under APP|
|#321 CAHPS for MIPS (#321)||✓||✓||Survey Vendor|
|#479 HWR Readmission Rate (#479)||✓||✓||CMS Administrative Claims|
|#480 MCC Unplanned Admissions (#480)||✓||✓||CMS Administrative Claims|
|#001 HbA1c Poor Control (#001)||✓||✓||EHR, Registry|
|#134 Screen for Depression and Follow Up (#134)||✓||✓||EHR, Registry|
|#236 Control of High Blood Pressure (#236)||✓||✓||EHR, Registry|
|Web Interface Measures no longer reported under APP:
Screen for Falls Risk (#318)
All Patients, All Payers
The most significant change is reporting on all patients across all payers under the APP. This change will require planning and preparation. Most APMs will need to move beyond chart abstraction to efficiently gather the required measure performance, or numerator, data.
How to Prepare for the APM Performance Pathway
Here’s what APMs and their members will need to prepare for:
All patients and all payer data: just as the diagram above illustrates, all patient visits across all payers must be reported on via the APP and the three quality measures.
eCQM vs CQM Scoring (EHR vs. Registry): you’ll want to review the measure specifications and benchmarks carefully to understand which submission mechanism is best for your organization. You’ll notice benchmarks vary by collection type.
Aggregating data across multiple EHRs and billing systems: most ACOs will have members on more than one EHR. Unfortunately, you cannot combine QRDA-III files from different EHRs into a single EHR submission. This is because each EHR has independently been certified, such as CHERT 2015, and workflows and data structure across EHRs does not match. You’ll want to consider an alternative participation mechanism if you have multiple EHRs such as a Qualified Registry which is capable of combining data from multiple sources.
Participation at the individual and group entity level: new in 2021, member entities of the APM can also participate in the APP or MIPS and retain the score which is highest; this is an advantage for members who have stronger performance than the APM entity or want to submit measures that are not included in the APP. Will you need to support them with data? Project management?
Workflows across locations, systems, and EHRs: How do workflows vary across the ACO? It’s important to know how care is documented to be able to extract and aggregate data for quality reporting like the APP.
Vendor capabilities and certification: no matter the method you choose, you’ll need to understand your vendors’ ability to report and/or extract necessary data. Is your EHR updated to 2015 CHERT? Understand what’s possible and timelines as soon as possible.
Benefits of utilizing a Qualified Registry for APM Performance Pathway Participation
As a Qualified Registry since 2012, Mingle Health understands the unique challenges of aggregating data and calculating quality measure performance, especially when it involves combining data from multiple sources and EHRs.
Here’s how a registry like Mingle Health will help you navigate the transition away from Web Interface:
Aggregating Data from Multiple Sources
As ACOs face the challenges that come with the transition away from Web Interface, they must have a partner that can support their unique needs. Mingle understands your organization may face data collection and reporting challenges if you are using multiple EHR platforms. Mingle Health can help you aggregate quality data from multiple EHRs before your final submission to CMS.
Understanding Your Performance
Mingle Health’s quality management tools and Quality Consultant support allows you to plan, track and optimize your quality data reporting and performance. We simplify the performance monitoring process at the ACO, TIN and clinician level, making it possible to track and manage your quality metrics throughout the year, not just at submission. This added focus on performance management will lead to higher incentive payments and improved outcomes for your patients.
|Capability||EHR||Mingle Health||Other Vendors|
|Dedicated advisor and consultant to guide you through the process||✓||?|
|Aggregate data across EHRs & PM systems||✓||✓|
|Expert support navigating requirements that change annually and support after submission to CMS during targeted review||✓||?|
|Review data before it’s sent and submit the required format to CMS||✓||✓||✓|
|Drill-down by practice, clinician, and patient-level to understand measure performance||?||✓||✓|
|Supplement EHR data for more complete view of care delivery and quality||✓||?|
Proven Quality Reporting Experts
As an industry leader in MIPS Reporting and ranked as a top performer by KLAS, Mingle Health combines easy-to-use software with a consultative approach, helping practices of all sizes succeed with their Quality Reporting. We have experience working with large academic medical centers, hospitals, billing companies, multi-specialty clinician groups, small groups and solo practitioners.
Experts You Can Count On
Dedicated consultants will guide you every step of the way. At Mingle Health, you’ll have an expert to guide you through every step of the quality management and CMS submission process. Our tools and consultants will help you plan, track, and manage your entire MIPS reporting cycle.
Next Steps – Talk with an Expert
The Mingle Health team would love to speak to you about your organization and considerations for making the transition away from Web Interface. Get in touch with us today or share your questions in the comments.
Join Mingle Health experts to learn about the transition away from the Web Interface mechanism.