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How to Improve APP Quality Scores, the end of the Web Interface, and more!

In this episode of Ask Dr. Mingle, Dr. Dan Mingle explains how to improve APP Quality scores, offers insight into the end of the Web Interface, and clarifies Promoting Interoperability and Improvement Activities rules for APMs.

Click play to listen to this week’s episode right now:

Question One: APP after Web Interface

Maryellen asks: “Will the APM Performance Pathway (APP) persist after the Web Interface retires?”
  • The short answer is yes.
  • The APP is the new scoring standard for the Medicare Shared Savings Program (MSSP), and it refers to all the elements of quality, performance, measurement, and scoring.
  • The APP includes the CAHPS Survey Measure, two CMS Administrative Claims Measures, and three submittable measures.
    • The three submittable measures are HbA1C Poor Control, Screening for Depression and Follow-up, and Control of High BP. These three measures can either be satisfied by eCQMs or MIPS CQMs.
    • In the intermediate phase between the announcement of the APP and the sunsetting of the Web Interface, you can satisfy reporting requirements using the ten Web Interface measures or the three APP measures.
  • Starting in the 2025 Performance Year, the APP is your only reporting option, and you’ll have to implement eCQMs or MIPS CQMs to satisfy requirements.

Question Two: Web Interface Sunsetting

Maryellen asks: “Is the sunsetting of the Web Interface subject to the payment year 2023 Final Rule, or has that ship already sailed?”
  • This question is a little bit harder to answer. In a way, the ship has already sailed. The 2022 Final Rule established the sunset of the Web Interface, and following the 2024 Performance Year, no other rulemaking needs to happen for the Web Interface to end.
  • But, things can change. Pandemics and other disasters happen, legislation passes, and intentions and rules change.
  • The 2023 Proposed Rule doesn’t alter expectations for the end of the Web Interface, so the Final Rule is unlikely to change anything.
  • The 2024 and 2025 rulemaking cycles are still ahead of us, and CMS could change things in that period. But with every day that passes, the end of the Web Interface gets more enmeshed in other rules, preparations, and plans.
  • At this point, there’s a bigger chance of postponing the end of the Web Interface than canceling the rule altogether.

Question Three: PI and IA for APMs

Karen asks: “For an APM, what are the requirements for Promoting Interoperability (PI) and Improvement Activities (IA)?”
  • Rules can vary across APMs, so the requirements for these elements will vary.
  • All APMs must have 75% of their participants on a certified EHR; the other 25% can be on non-certified EHRs or paper charts.
  • If you’re a Qualified Participant (QP) in an Advanced APM, MIPS doesn’t apply to you, so you don’t need Promoting Interoperability or Improvement activities.
  • If you’re participating in a MIPS APM or not a Qualified Participant in an Advanced APM (meaning you don’t hit the threshold number of patients to be a QP), then you’re subject to the MIPS rules.
    • And the MIPS Rules don’t change much in this case:
      • You don’t have to have a certified EHR, but you’d be sacrificing potential performance points for Promoting Interoperability if you don’t have this in place.
      • For Improvement Activities, CMS will grant you half of the Improvement Activity points just for participating in an APM.
      • CMS also recognizes other Improvement Activities in the process of approving an APM, and they can grant additional points to organizations that meet their IA requirements.
  • All APMs earn full Improvement Activities credit for all participants at this time. So, if you are a MIPS participant in an APM or didn’t achieve qualified status in an Advanced APM, you’ll still get your full score for Improvement Activities.

Question Four: How to Improve APP Quality Scores

Chandra asks: “What is your recommendation to improve our APP Quality scores?”
  • Switch as soon as you can from the Web Interface to MIPS CQMs. This option gives you the most freedom and potentially the highest scores. In a previous episode, Dr. Mingle explained why MIPS CQMs are a better option in more detail.
  • It’s not too late to engage your registry to submit MIPS CQMs to satisfy the APP in 2022. At Mingle Health, we’ll accept APP clients through January 1, 2022 (and maybe even longer).
  • You could choose to make a simultaneous Web Interface submission with a MIPS CQM APP submission.
  • But, it might be a better investment of your time, money, and effort to engage a registry to do a preliminary run of your data for the first three quarters of 2022. Then, your registry can help you audit your results:
    • Your registry should be able to give you a list of specific patients in each denominator with their met, not met, or excluded statuses.
      • Auditing about 30 patients (at a minimum) will allow you to do a preliminary check of data accuracy. This will be the first of many steps to steadily improve your measurement accuracy.
      • In fact, you should start thinking of improving the accuracy of your measurements as a lifelong improvement process.
    • In the final processing of the entire year’s data, you should take a list of all your denominator patients that fail each measure and manually check the chart.
      • It’s appropriate for your registry to add manually abstracted data to the submission to improve your scores.
    • As you audit, determine why performance met data was not detected in the electronic data set. This will allow you to go back and correct the templates that aren’t capturing data correctly or provide supplemental training for your users, so they know where to record data.
    • You’ll find that your scores depend on clinical performance, of course, but they will also rely on proper documentation, workflows, and effective data exchange.
  • If you start this process now, you’ll be able to enjoy the relaxed Quality standard for the APP before the Web Interface finally sunsets.

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:

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
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