In this episode of Ask Dr. Mingle, Dr. Dan Mingle answers questions about collection type options for the newly proposed APM Performance Pathway (APP) Plus and then provides an in-depth explanation of MIPS Value Pathways (MVPs) vs. other reporting options for specialty practices.

Click play on the video below to listen to this episode now, or scroll down for the written summary.

Question One: eCQMs vs. Medicare CQMs for APP Plus

Gloria asks: “eCQMs and Medicare CQMs are the proposed collection types for APP Plus. Can you explain the difference between these two options?”

You have recognized that in the Proposed Rule for the Quality Payment Program for 2025, Medicare has proposed to limit the APM Performance Pathway (APP) for Accountable Care Organizations (ACOs) in the Medicare Shared Savings Program (MSSP) to the options of eCQMs (electronic Clinical Quality Measures) and Medicare CQMs, proposing to eliminate, only for MSSP participants, the option of submitting MIPS CQMs.

If this proposal is finalized in the 2025 Final Rule, MIPS Participants can use:

• MIPS CQMs
• eCQMs
• MIPS Value Pathways (MVPs)
• And there are some special circumstances:
  • Small practices (15 providers or less) can use Claims-based submissions
  • Facility based providers can choose to use the assigned facility’s quality score, if there is one

And MSSP participants can use:

• eCQMs
• Medicare CQMs

And the Web Interface will finally sunset after the 2024 performance year, so it will not be an option in 2025 or afterward.

I think it is a big mistake by Medicare to eliminate MIPS CQMs as an option for MSSP ACOs to report via the APM Performance Pathway, and I expect they will get plenty of criticism for this proposal. Eliminating MIPS CQMs for MSSPs will push back a lot of the progress made in value-based care. I’ll explain my rationale on this topic in a future episode of Ask Dr. Mingle.

To explain the differences in your options for the APP:

• All quality measures, whether MIPS CQMs, eCQMs, or Medicare CQMs, share a similar structure:
  • Each has specifications that describe the patient-visits eligible for the measure
  • Each has specifications that describe the health care interventions that qualify as desirable
  • The output is the ratio of patient-visits that received the desired intervention divided by the number of patient-visits eligible for the measure.
• But these methods differ by:
  • The acceptable data sources that can be used
  • The requirements that an outside vendor assist you
  • The cohort of patients considered

Let’s take a look at each collection method and I’ll explain the differences between your options. I’ll include MIPS CQMs in this overview, because as mentioned above, I think it is important that they continue to be an option for MSSP ACOs.

MIPS CQMs:

• Permits any accurate data source. Any place you can find and deliver appropriate data is eligible for use in your MIPS CQM submission. Some example sources could be:
  • Your EHR system.
  • Manual chart abstraction.
  • Clinical registry data sets, like a cancer registry.
• All patients of all payers of participating practices are included in MIPS CQM denominator specifications.
• You work with a vendor to create a MIPS CQM submission. These vendors are called “Qualified Registries”:
  • Qualified Registries are subject to rules and oversight by Medicare, and they must be qualified annually.
  • The accuracy of their work and measurements are subject to audit by Medicare, and Registries can be censured or disqualified for departures from requirements.

Medicare CQMs, a small but significant departure from MIPS CQMs:

• The patient population eligible for denominator inclusion is only Medicare part B beneficiaries – no other patients of any other insurer are eligible.
  • Otherwise, denominator eligibility specifications are word-for-word identical to those of MIPS CQMs.
• Everything else matches MIPS CQMs:
  • Permissible data sources are the same.
  • Vendor qualification requirements are the same – all vendors qualified to provide MIPS CQMs are also qualified to provide Medicare CQMs.

eCQMs:

• eCQMs are electronic Clinical Quality Measures, and their specifications are formatted differently than MIPS CQMs and Medicare CQMs. The meaning is the same in their specifications, but acceptable electronic data labels and meanings are added.
• For both numerators and denominators, the data sources are restricted to electronic sources with a direct path to the Certified EHR.
• eCQM vendors are not “Qualified” as are Qualified Registry Vendors, but they are Certified as EHRs.
• eCQM submissions must be created by a certified vendor from a certified EHR data source.

It’s important to note that:

• Qualified Registries can use, even exclusively, the same electronic data as eCQM vendors.
• eCQMs are, by definition, digital in nature. They must use certified EHR data.
• Qualified Registries can be digital in nature. They can voluntarily choose to be digital; they can voluntarily restrict themselves to Certified EHR data. And if specifications for a measure require it, they can restrict themselves to only Certified EHR data.
  • But they can also use a broader electronic data set than eCQMs. They can use accurate electronic data from uncertified sources if needed.

In the case of APP (and now APP Plus) reporting, the certification requirements for eCQMs can be a significant barrier. These requirements can dramatically increase the expense of quality reporting without improving accuracy.

Question Two: MIPS Value Pathways (MVPs) for Specialties

Jean asks: “If my specialty has a hard time finding appropriate measures, should I use MVPs?”

Not necessarily!

Since Medicare started asking for quality data to be submitted, we have suffered from the phenomenon that there are many practices that do not have adequate or appropriate measures that are submittable.

MVPs are not designed, like Specialty Measure Sets or EMA clusters (Eligible Measure Applicability clusters) to deal, specifically, with inadequate measure availability. They tend to be as good as specialty measure sets to deal with inadequate measures, but with a different set of complexities or nuances.

Let’s take a look at your options when choosing measures for your specialty to better understand the strategies that may work best for you.

EMA (Eligible Measure Applicability) clusters:

• EMA clusters are a number of measures that are grouped together in defined groups with similar clinical topics and/or eligibility specifications.
• Medicare assumes that if you submit one of those measures, you can submit all of those measures.
• If you submit all of the measures in an EMA cluster, you get full credit for a quality submission even if the measure set includes only two measures.
• This can work even for practices that don’t have patients that qualify for one or more of the other measures in the EMA cluster:
  • An EMA submitter who can truthfully and accurately submit a “0” for the denominator of one or more of the EMA cluster measures gets a full quality score for the submission.

Specialty Measure Sets:

• For 2024, Medicare has defined 51 specialty measure sets.
• These are a suggestion, not a requirement, for specialty practices.
• Some of these Specialty Measure Sets have fewer than six measure choices. Submitting all of the measures in a set, even if there’s less than six, counts as a full, unpenalized quality submission.
• Like EMA clusters, a practice or provider can submit measures with a “0” denominator, and as long as that is true and accurate, they’ll get full credit for the Quality category.

And MVPs are designed to function in a similar way to Specialty Measure Sets, with some important nuances:

• Your MIPS submission is limited to the items outlined in the specific MVP you’re submitting.
  • MVPs are coordinated or limited to topically appropriate Improvement Activities and Cost measures.
• If things continue as scheduled, after 2024, MVP submissions will be restricted to providers eligible for the MVP in your organization. There’s a chance that you’ll need to submit more than one MVP for your organization if there isn’t a change in the rules.

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 hello@minglehealth.com.

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

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.

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