In this episode, Dr. Dan Mingle provides a detailed explanation of the CMS Web Interface and shares additional insight into MIPS requirements for MSSP ACO participants.

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Question One: CMS Web Interface

Crystal asks: “Can you explain the CMS Web Interface for quality reporting? We are part of an ACO that has many different EMRs, and we are unable to submit an eCQM QRDA.”

The CMS Web Interface has been an option for quality reporting since 2013.

It’s been a requirement for the Medicare Shared Savings Program ACOs to meet their quality reporting obligations, and it’s been an option for group practices with 25 or more providers to complete their MIPS quality reporting obligations.

In the current model of the Web Interface, Medicare delivers to each participating practice or entity, at the close of each performance year, a list of attributed patients eligible for each of the 10 measures of the Web Interface.

The entity must report performance against the measure on the first 248 patients on each measure’s patient list.

248 patients for each measure multiplied by 10 measures equals 2,480 chart abstractions to complete each episode of quality performance analysis.

• It seems a daunting task until you realize, first, many of the measures group together so that a single chart abstraction serves multiple measures. Second, when your group is more than 25 providers, it averages out to 10 patient charts per provider per measure, which is quite doable in healthcare systems that may be caring for hundreds of thousands of patients.
• The annual process compares favorably in effort and cost to the electronic processes required to tame the data chaos in most healthcare communities.
• If your goal is a simple annual estimation of quality performance on a statistically significant sampling of patients, you would continue to use the Web Interface chart abstraction process.

But annual chart abstraction is a dead end that does not lead to the many benefits that should come from your quality measurement system.

The data and processes behind annual quality measurement and reporting have many other potential uses that are desirable in a high-value healthcare system:

• Performed repeatedly, it is the foundation for a quality improvement system.
  • Annual measurement is too infrequent to drive quality improvement. You need at least quarterly, if not monthly, or weekly measurements to power any credible quality improvement process.
• It is also the same data you need to analyze gaps in care. Your quality assessment system should ultimately be used as a decision support tool at the time and place of care.
  • It’s the same data, the same process refreshed at least weekly, if not daily, or at the moment of care. The value of quality is not restricted to our Medicare patients, to which the Web Interface is limited, but it applies to all patients of all payers.
• Ultimately, when we have mastered the infrastructure, the overall quality of our care is not dependent on our care of diabetes, hypertension, and depression, as implied by the APP measure requirements. Overall quality depends more on our success in distributing tens of thousands of evidence-based rules that you’ll find in scrutiny of health care literature.

For these and other reasons, Medicare has decided to sunset the Web Interface quality assessment system in favor of measuring the quality of care across all patients and all payers.

The current expectation is that you can use the Web Interface to assess the quality of your care in your ACO for the 2023 and 2024 performance years.

After that, you will need to use eCQMs or MIPS CQMs to measure the quality of care in your ACO for all patients of all payers

In getting back to the core question, Crystal implies that you have two choices: eCQMs that won’t work and the CMS Web Interface that will sunset after the 2024 performance year.

• Let’s face it. eCQMs are just not ready for prime time. In the long run, they are as much on the technical side as Web Interface is on the manual side.
• ACOs will find that the only affordable, scalable, and sustainable systems will be built on MIPS CQMs.

Here at Mingle Health, we have been making MIPS CQMs work in complex environments for over a decade. We have successfully and affordably normalized data and matched patients across disparate electronic health records and practice management systems during this time.

Question Two: MIPS Requirements for MSSP ACO Participants

Di Asks: “If you are participating in a Medicare Shared Savings Program ACO, what is your MIPS requirement? Is Promoting Interoperability still required?”

The answer to Di’s question depends on two things:

1. If your MSSP is an Advanced APM or a MIPS APM.
2. And, what is your participation status if your MSSP is an Advanced APM? You could be a Qualified Participant, a Partially Qualified Participant, or neither.

An explanation of Advanced APMs vs. MIPS APMs:

• Your APM entity leadership can tell you which one you’re participating in:
• It depends on the level of risk your ACO has accepted, through a contract, with Medicare.
  • Risk is about actual costs vs. predicted costs of providing one year of health care to all the patients attributed to your MSSP ACO.
  • All MSSPs, whether advanced APMs or MIPS APMs, share in savings if your total cost of care for your patient panel comes in under budget.
  • Advanced APMs typically have the potential to earn a larger share of any savings than a MIPS APM.
• But to earn that right to a larger share of the savings, Medicare requires your MSSP ACO to take more than nominal downside risk.
  • Downside risk means if your ACO comes in over budget on the cost of one year of care for its attributed patients, the ACO will share in the loss.
    • Medicare considers 8% to be the threshold of Nominal Risk.
    • If your ACO does not share in the loss when there is a loss, then yours is a MIPS APM.
    • If you share in the loss but your share is under 8%, yours is a MIPS APM.
    • Yours is an Advanced APM if the ACO will collect a share of any savings generated, and if there is a loss, the ACO will be liable for 8% or more of the loss.

If your MSSP is a MIPS APM, you are subject to MIPS scoring and adjustment. It’s not the same as the general MIPS requirement (we’ll see the differences below).

If your MSSP is an Advanced APM, your MIPS requirement also depends on your status in the ACO:

• Status relates to what proportion of your eligible patients receive care through the ACO.
  • Participation is measured by the proportional amount of charges and the count of patients. You are judged by whichever calculation is most favorable to you.
• There are two thresholds for each number:
  • If you meet the higher threshold, you are considered a Qualified Participant or “QP”.
  • You are considered a Partial QP if you meet the lower threshold but not the higher one.
  • If you did not meet either threshold, you are subject to MIPS.
  • If you met the lower threshold only, as a partial QP, you choose whether or not you will participate in MIPS.

And finally, if you are in an APM and subject to MIPS, scoring is slightly different than for mainstream MIPS:

• Cost does not count into your MIPS score because Cost performance is accounted for contractually with Medicare through shared savings and/or losses.
• Quality accounts for 50% of your MIPS score.
• Improvement Activities accounts for 20% of your MIPS score. All APM participants are granted half the available IA score just for participating. Medicare reviews all APM designs and grants additional IA scores based on APM requirements.
  • Currently, all APMs earn 100% of the available IA score. No submission is necessary.
• Promoting Interoperability is required and accounts for 30% of the MIPS score.
• You can submit individually, and your practice can submit as a group.
• Finally, new for 2023, your APM can submit for all participants.

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.

Download the APP Checklist

As the Web Interface sunsets, ACOs must prepare to transition into the APM Performance Pathway (APP) reporting method by Performance Year 2025. For many ACOs, this task is daunting - with data challenges, technical hurdles, and a completely new reporting workflow. To help with this, we've created the APM Performance Pathway Checklist - a two-page resource to assist your organization in understanding and preparing for this challenge.

Access the Checklist