In this episode Dr. Dan Mingle explains what MSSP ACOs should take into consideration as they transition from the Web Interface to APM Performance Pathway reporting. Later, Dr. Mingle shares advice for navigating MIPS and aiming for positive adjustments as the program gets tougher.
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Question One: Supporting APM Performance Pathway (APP) Reporting
Georgina asks: “We are a Medicare Shared Savings Program (MSSP) Accountable Care Organization (ACO) transitioning from the Web Interface to the APM Performance Pathway. What should I consider to optimally manage our participants to support APP reporting?”
The big difference between Web Interface and APM Performance Pathway reporting is the number of data points you need.
The Web Interface requires 248 patients for each measure. ACOs can achieve this by distributing the pertinent subset of the required 248 patient identities to the practices that hold data on those patients and manually abstracting the charts to answer the “is performance met?” question.
But the all-patients, all-payer requirement of eCQMs and MIPS CQMs makes manual chart abstractions prohibitively expensive. Even the Proposed Medicare CQMs option is an enormous lift to perform with manual chart abstractions.
No matter what method and vendor you choose to meet the APM Performance Pathway reporting requirements, there is a basic set of prerequisites you will need to fill:
- You need to know your participating practices. This means keeping track of:
- Participating providers
- Key contacts
- You need to have an inventory of Health IT systems in use, like:
- Practice management systems
- Electronic Health Records
- System vendor with key contacts
- Hosting vendor with key contacts
- And data access contacts
- You may find that there are multiple options to get data from each practice and each system:
- You’ll need to identify the strengths and barriers for each practice and its vendors.
- You’ll need to choose a workable method for each system and practice and then implement it.
- Your options for getting data could include:
- A database technician to extract the needed data from the systems
- The person who writes the extraction can be from the practice, the product vendor, the hosting vendor, or a third party.
- If a third party, that party needs access to the data through the hosting vendor.
- A Practice member triggering canned reports that include the data needed:
- You can accomplish this with automated electronic data exchange per interoperability capabilities in your systems.
- Or manual chart abstraction
- A database technician to extract the needed data from the systems
And there needs to be someone assigned to do the APM Performance Pathway reporting work:
- That person can be from the ACO.
- Or the work can be contracted from:
- The Quality reporting vendor or registry
- The integration vendor
- Another third party vendor with the needed skills and experience
- We’ve found some common barriers to this basic organizational step:
- It takes a substantial amount of time, knowledge, and experience to do it efficiently and effectively.
- ACOs never have excess staff with enough time to do it.
- More often than not, participating practices are reluctant to share data with their ACO. They may be willing participants and partners in the ACO, but are competing with other ACO participants in many other aspects of local care.
- A neutral third party mediating the details is often necessary for global cooperation.
Once your APP workflow is up and running, routine maintenance is required:
- Errors in the data are inevitable. They need to be recognized, understood, and addressed.
- Practices will upgrade their systems, which often changes the data flow, creating new errors that must be recognized, understood, and addressed.
- Practices will change systems and/or hosting vendors, requiring a new assessment of the best way to get data.
- New practices and providers will join the ACO, each requiring a new assessment of their HIT infrastructure and decisions for optimal data exchange.
Question Two: MIPS Positive Adjustment Post-COVID
Charlene says: “I understand I am going to have to work harder to earn a MIPS Positive Adjustment as the program picks up again and matures post-COVID.”
You are absolutely right. MIPS is getting harder. Earning the total 30 points in Quality is becoming more critical to achieve adjustments in the positive range. It’s certainly achievable, but it is hard.
CMS publishes the score you need for each measure in advance, based on national scores two years before the current performance year. The required performance to get a specific score is knowable but not necessarily easy. It will take a coordinated effort of your whole practice to achieve optimum results.
Here are some tips:
- Plan the care of your patients. Planning care is vital around all aspects of care, and it is essential around your target measures.
- Track who in your practice will ask the questions, take the measurements, or explore the record to determine the necessary care.
- Record indicators in a standard place in the electronic chart that is electronically recoverable to measure your performance.
- You need to know who in the practice will provide the care and how they will learn that it’s required.
- The person who provides the care should optimally work from a protocol.
- The protocol must be correctable. You must not be locked into the protocol.
- The practice response to deviations from the protocol should begin with examining the protocol to see if it needs to change.
- Record the care provided in a standard electronically recoverable place to measure your performance.
- You must measure regularly, rethink and rewrite your protocols, reassign and retrain your people, and build or correct EHR documentation templates as indicated.
As you struggle with periodic adjustments to your Quality reporting infrastructure, always look for choices to keep your Quality reporting scalable, flexible, and affordable.
- Scalable: You will need to add more measures for the same program or additional programs requiring different measures.
- Flexible: You must change measures as old measures top out, new medical evidence renders current measures obsolete, or new health priorities require a new focus on measures.
- Affordable: You need a single infrastructure configurable for any conceivable measure. You should never “jury-rig” a measurement infrastructure for a specific measure. You should have standard places in your data system where you can find structured data to identify with an electronic query:
- All expected permutations of denominator specifications
- Age, sex, risk factors, chronic diseases, recurrent conditions, medications, allergies, lab results, vital signs
- All expected permutations of exclusion criteria
- All expected permutations of numerator criteria
Clinical and documentation workflows should make sense even beyond the context of data for quality reporting.
Your routine workflows should serve as efficient and effective documentation and a source of reliable data for quality reporting.
Send us your value-based care questions!
If you’d like to ask a question about the APP transition, MIPS, 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 firstname.lastname@example.org.
For many ACOs, the transition to all-patient, all-payer quality reporting is a significant challenge and often feels like an unnecessary burden imposed by CMS. We've created our latest PDF guide to help ACOs orient themselves to the challenge of all-patient, all-payer reporting while finding opportunities to thrive in the future.