This episode of Ask Dr. Mingle features insight into eCQM challenges, why Digital Quality Measurement doesn’t necessarily equal eCQMs, why it’s worthwhile to improve ACO quality scores, and what to expect in the final years of the Web Interface.

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Question One: eCQM Challenges

Tiffany asks: “I know you’ve been working with practices for nearly a decade to report MIPS and PQRS. What have practices found to be the biggest challenge in using eCQMs from their EMR to report quality?”

• The two main problems with eCQMs, in Dr. Mingle’s experience, are the rigidity of the process and the expense involved.
• Expenses can vary across different EMR vendors, but they are relatively expensive compared to MIPS CQMs.
• The rigidity of eCQMs is where most organizations will run into trouble:
  • There are roughly 48 eCQM options, compared to around 170 MIPS CQMs. But most EHR vendors are selective about which of the 48 eCQMs they’ll support, and they’re not required to support all of them.
  • eCQMs can be produced by a single EHR vendor, or multiple vendors can be involved in getting the data from the documentation into a submission. But every step of this process must be certified, or the entire submission is invalid.
  • Without solid documentation standards and compliance with those standards, eCQMs are unlikely to work. When was the last time you had a group of doctors agreeing on the best way to document?
  • EHR vendors cannot quickly adapt eCQMs to changing standards from CMS. Most eCQMs are coded into EHR software and updating the software to match new standards takes time.
• In Dr. Mingle’s experience, small organizations can usually overcome these problems because they have limited employees on a single instance of a single EHR platform.
• As organizations grow, or in the case of ACOs, the barriers to eCQM submissions increase substantially.
  • Within a large organization, some practices may be on different EHR platforms or different instances of the same EHR platform. In either case, eCQMs are much more challenging.

Question Two: Digital Quality Measurement and eCQMs

José asks: “Medicare has introduced Digital Quality Measures. Won’t we have to use eCQMs to comply with digital measurement?”

• There’s been quite a bit of confusion about the announcement of Digital Quality Measures. But there’s no reason to think that Digital Quality Measurement equals eCQMs.
• Dr. Mingle mentions that when he first read about Digital Quality Measurement in the 2022 Rulemaking cycle, it sounded to him like a desire from CMS to use any digitally coded data set to go after measures and a goal to get all measures from digital sources. In Dr. Mingle’s opinion, these are two laudable goals. But CMS didn’t provide a time frame to reach either.
• At the NAACOS Fall 2022 Conference, a representative from CMS described the concept as signaling an intention to embrace quality measurement that incorporates a wide variety of digital sources, not just EHR data. These digital sources could include remote patient monitoring, wearable technology, and direct patient input technology.
• There are no actual Digital Quality Measures currently. The Qualified Registries using MIPS CQMs will likely use the new format more easily than those using eCQMs from an EHR vendor when and if Digital Quality Measures are available.
  • Remember that in the eCQM process, you must use a certified data chain for a valid submission. To utilize the plethora of wearable devices and remote patient monitoring options available, EHRs must internalize that data to ensure it’s part of the certified eCQM process.

Question Three: ACO Quality Scores

Karen asks: “We are joining a newly formed MSSP ACO. The ACO leadership is saying that they’re not concerned about the quality scores, and that’s something that our practice is working hard to improve this year. Should we not be concerned about quality scores?”

• It’s important to keep working on your scores, but don’t be concerned about an ACO not worrying about scores in the first year.
• Quality reporting is pay-for-reporting in the first year of participation for a new MSSP ACO. Your scores don’t matter as long as you can get your data in and meet the quality performance standards for ACOs.
• After the first year, you will have to meet the numerical standards to earn shared savings.
• Even with the relaxed rules in the first year, the work to improve scores is essential. It’s important now (and in the future), or you’ll be behind in the coming years.

Question Four: What to Expect as Web Interface Ends

Maryellen asks: “What can we expect from 2023 to 2025 if we’re part of an MSSP ACO using Web Interface?”

• During the APM Performance Pathway (APP) transition, it’s a good idea to keep Web Interface as a temporary option to produce quality measures in the next couple of years.
• If you’re using the Web Interface, you’re required to report ten measures, and most organizations use chart abstraction to get that data from their EHRs.
• Once the Web Interface sunsets in 2025, you’ll be required to produce three measures with either eCQMs or MIPS CQMs.
• If you stay with the Web Interface in 2023 and 2024, things won’t look much different to you than they always have. But there are some things to be aware of:
  • The Quality Performance Standard is staying at 30% for 2023, but it will go up to 40% in 2024. This may reduce your chances of collecting shared savings or protecting from shared losses.
    • CMS estimates that about 40% of practices will have difficulty hitting the new 2024 standard.
• Organizations that move from the Web Interface to the APP early (before the end of the Web Interface in 2025) will get a break on the performance standard:
  • Instead of your organization’s aggregate scoring being 30% in 2023 and 40% in 2024, only one of your measures has to hit the respective year’s goal, with one additional outcome measure being at least 10%.
• This break in scoring, and the preparation required to satisfy APP requirements with either MIPS CQMS or eCQMs, provides a strong incentive to switch early.

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