In this week’s episode of Ask Dr. Mingle, Dr. Dan Mingle explains how ACOs can meet APP Quality Reporting requirements and shares some insight into eCQMs and FHIR standards.

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Question One: APP Quality Reporting with MIPS CQMs

Jeff asks: “I’ve heard you say that we should satisfy APP Quality Reporting with MIPS CQMs. Why is that?”

• MIPS CQMs offer a much more scalable, sustainable, and affordable solution to the APP reporting requirements.
• Most ACOs consist of multiple independent practices, and these practices usually have different EHR systems.
  • 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.

Question Two: eCQMs and APP Quality Reporting

Meg asks: “Why shouldn’t I use eCQMs to satisfy the APP?”

• Many EHR platforms can generate eCQMs for quality reporting, but this process is often unsustainable under real-world conditions.
• There are multiple failure points in the eCQM reporting workflow:
  • eCQMs require rigid compliance with documentation workflows. You could be fulfilling all of the requirements for a given measure – but if you’re not documenting it correctly in your EHR, your eCQMs won’t work.
  • CMS rules can change more rapidly than EHRs can upgrade. Medicare rules change yearly in the annual rulemaking cycle, but CMS can also issue “post-regulatory guidance” to change requirements at any time. Most EHRs cannot match the pace of changing specifications with software updates.
• The problems listed above apply to eCQMs in any setting, but for ACOs, additional difficulties arise:
  • To satisfy the APP requirements, ACOs must create an integrated data set from different EHRs across their organization.
  • Building a process for capturing and integrating data into a single data set is expensive and time-consuming.
  • But, if an ACO does manage to build a system for integrating their data, they’ll still have to ensure the data is reliable and properly documented, de-duplicate patient records, and maintain the data set regularly. Additionally, if one link of their eCQM reporting workflow is not ONC certified, they’ll no longer have an end-to-end eCQM solution (which means the system will not satisfy APP requirements).
  • ACOs also have the challenge of adding additional practices to their organization or changing EHR systems in their organization.
    • As an added difficulty, even if all the practices in an ACO are on the same EHR system, eCQMs are still unlikely to work correctly unless those practices are on the same instance of the EHR.

Question Three: eCQMs and FHIR

Alex asks: “FHIR is coming. Does that mean I need to do eCQMs to be FHIR ready?”

• In short, no. Here’s some helpful context:
  • FHIR is one specific type of Health Level Seven International (HL7) standard, and it is the latest in a family of outputs called Clinical Document Architecture.
  • FHIR shares the same control characters and syntax as previous HL7 standards, so anyone capable of handling previous HL7 message types can read and write FHIR.
  • Previous HL7 standards and FHIR are not exclusive to eCQMs. Any registry providing MIPS CQM reporting capabilities can include FHIR sources in its services.
  • As more and more users embrace FHIR, you shouldn’t expect any issues to arise whether you utilize eCQMs or MIPS CQMs.

Send us your value-based care questions!

If you’d like to ask a question about the APP transition, MIPS, Primary Care First, ACO quality reporting, or any other Alternative Payment Model, you can reach out to us in three ways:

• You can leave your questions in a YouTube comment under any episode of Ask Dr. Mingle.
• On LinkedIn, leave your questions in a comment on any of our posts.
• And you can reach out directly by sending an email to hello@minglehealth.com.

Want to learn more about the APM Performance Pathway (APP)?

Access the recording of our webinar: "2022 Final Rule & the End of Web Interface: How to Make the Transition to CQMs" for additional information about the steps required to make the transition away from the Web Interface mechanism and the capabilities necessary to make the process as smooth as possible.

Access the Webinar Recording