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eCQMs are not the only option for the APM Performance Pathway (APP) for ACOs: Benefits of CQMs and Qualified Registry

CMS announced the transition to the APM Performance Pathway (APP) for MSSP ACOs in the 2021 Final Rule. The program requires reporting three quality measures for all-payers, all-patients, just like MIPS. The goal is to encourage ACOs to measure and report on their entire population served.

In contrast, ACOs have previously been able to utilize a sampling methodology, called Web Interface, to report 10 quality metrics for only 248 patients selected by CMS via a chart abstraction process.

In the 2022 Final Rule, CMS formalized the transition plan: ACOs will receive favorable quality scoring if they begin the transition to MIPS CQMs/eCQMs sooner (as early as 2022). They can also use the Web Interface mechanism until the 2024 performance year but must make the change starting in 2025.

As ACOs plan their transition to APP quality reporting with MIPS CQMs/eCQMs, many are initially seeking to leverage their EHR exclusively without engaging an additional vendor.

eCQMs vs. MIPS CQMs: How should ACOs proceed with their MSSP reporting?

In practice, despite being granted more time to make the transition by CMS, ACOs are learning that using eCQMs, rather than MIPS CQMs, from their EHR(s) is going to take longer, cost more, and show lower performance than expected. Further, most ACOs have multiple EHRs and eCQMs do not support the combination of data across systems.

Healthcare Innovation contributing senior editor, David Raths, recently published an article highlighting the challenges expressed by a panel of ACO leaders at the NAACOS Fall Conference in October 2021. In the article, Paula Burleson, manager of government programs at North Carolina-based Novant Health, shared: “As an organization, we have to involve lots of clinicians in the decision-making because the workflow might differ if the measure is specified differently, or even if exclusions are specified differently.”

Also quoted in the article, Megan Reyna, vice president of government and value-based programs at Downers Grove, Ill.-based Advocate Aurora Health, said: “With our web interface, if we needed to go back into the practice and abstract data, we could find it and abstract that colonoscopy. But now if they’re not documenting the colonoscopy in the place that the vendor is telling you it needs to be documented, it’s not going to be collected.”

But eCQMs are not the only solution for APP participation.

It’s a common misconception that EHR reporting is the only option to make the transition away from web interface reporting for ACOs. Medicare has made an additional option available: MIPS CQMs, which Mingle Health has helped thousands of organizations successfully measure and report since 2012. MIPS CQMs allow for data to be aggregated across EHRs from structured and unstructured data sources.

What’s involved in the transition? What quality measures should ACOs use – eCQMs or MIPS CQMs?

The biggest part of the transition is the change to the reporting methodology. Web Interface is a sampling methodology where 10 quality measures are reported for 248 patients. The patient list is calculated by CMS and shared late in the year. The new APM Performance Pathway (APP) requires organizations to transition to MIPS CQMs or eCQMs by 2024 and aligns more closely with MIPS, requiring reporting on all patients across all payers. This is because CMS is seeking to measure population health and care that is being delivered to all patients, not just care delivered to Medicare patients.


  APM Performance Pathway (APP) Transition
Reporting Mechanism Web Interface MIPS CQMs/eCQMs
Quality Measures Report 10 measures
for 248 patients
Report 3 measures
for all patients, all payers
Required Quality Thresholds 30th Percentile for each measure

40th Percentile starting in 2024

10th Percentile for One outcome measure & 30th for One other measure

40th Percentile for Each Measure starting in 2024

Aggregation Method Chart abstraction Electronic via supported data sources (eCQMs require single EHR on 2015 CHERT)

Continue reading for a comparison of eCQMs and MIPS CQMs for common ACO requirements.

In our recent webinar, Mingle Experts explain the transition and how to plan for success.
Download the slides here >>

Common ACO characteristics

As we consider what’s involved in the transition to the APM Performance Pathway and the new reporting methodology, let’s keep in mind the makeup of the typical ACO.

According to the National Association of ACOs (NAACOS), each MSSP ACO has an average of 35 tax ID numbers (TINs).  40% of MSSP ACOs have over 15 distinct EHRs.  One MSSP reports having 422 member-TINs using 65 EHRs.

Which participation option is best for making the transition to the APP?

eCQMs vs CQMs for APM Performance Pathway

Now, let’s compare the two participation options for the APP: The major difference between eCQMs (electronic clinical quality measures) and CQMs (clinical quality measures) is how the measures are calculated:

  • eCQMs: Calculated by certified EHR
  • CQMs: Calculated by CMS Qualified Registry

For most ACOs, CQMs (aka registry measures) are the better choice because ACOs need to bring together data from multiple EHRs, TINs, and locations. Let’s break down the key reasons why.

Comparison: How does each method collect data for measure calculation?

eCQMs: Single Certified EHR only. eCQMs must be generated from a single certified system. Most ACOs have members on multiple EHRs, all EHRs need to be certified.
CQMs: Multiple data sources. CQMs have the flexibility to use data from multiple sources, including multiple EHRs, and don’t require certification.

→ Winner: CQMs unless you only have one EHR.

Comparison: How many quality measures do each method support?

eCQMs: Smaller measure selection (47 total). EHRs often support only a subset of available measures; frequently not timely in making updates for changing measure rules & specifications

MIPS CQMs: All QPP measures. Qualified Registries like Mingle Health support all 47 eCQMs and 185 CQMs in the Medicare library; updates are made quickly.

→ Winner: MIPS CQMs. Technically, either could work if you don’t need all the measures; eCQMs are, at best, risky because EHRs are frequently late to release CHERT updates to meet measure specification and rule changes.

Comparison: How well does each method lend itself to measuring quality across multiple sites?

eCQMs: Fixed workflow across all sites. eCQM results are based on a specific standard EHR workflow for each measure. If those workflows aren’t followed consistently by all providers, measure performance may be low and not reflect actual care quality.

MIPS CQMs: Flexible workflows across sites. CQMs are not exclusively dependent on EHR workflows. Clinical data extracts can be tailored to reflect how providers actually use the system; using the right data means better performance.

→ Winner: MIPS CQMs unless all clinicians use the same workflow per specification.

Comparison: Which method is best for aggregating data across multiple EHRs?

eCQMs: Data from a single EHR. eCQMs are calculated within one EHR. Most ACOs have multiple EHRs and will need to find and purchase a certified solution to aggregate data across all their systems.

MIPS CQMs: Data from multiple EHRs. CQMs have the flexibility to use data from multiple sources (matching/de-duplicating patients is already part of the process). There is no new functionality to wait for or test out.

→ Winner: MIPS CQMs are the only way to aggregate data across multiple EHRs.

Comparison: Which method allows you to improve data quality and completeness as part of the measurement and reporting process?

cCQMs: Can only address data within the EHR in the fields that are pre-determined per the EHR’s implementation of the measure specifications.

MIPS CQMs: Able to bring in additional data sources/fields and abstract charts to fix missing information which improves performance

→ Winner: MIPS CQMs. All you need to start is billing data, layer in EHR data, and fill in missing data points from clinical data extracts and abstraction.

The Bottom Line: MIPS CQMs offer many advantages to ACOs

MIPS CQMs and Qualified Registries are the only solution for aggregating data across multiple EHRs and offer significant benefits for ACOs and the transition to the APM Performance Pathway. For ACOs with multiple TINs and more than one EHR, reporting CQMs with a Qualified Registry like Mingle Health is the only path to timely measurement and your best performance at a lower cost than the steep climb to success with eCQMs.

EHRs and the corresponding eCQM methodology don’t currently have a solution for combining data from multiple EHRs. Why should ACOs wait for a new solution that has yet to be released or proven?

When asked about eCQMs, Mingle Health’s Jason Schucker, Senior Healthcare Informatics Analyst, recently said:

“eCQMs are designed and coded very specifically, [providers] have to follow very distinct workflows. Clients want to report eCQMs, but the performance is just not that good. [Providers] aren’t checking the right box, they’re not putting in the right code.” Listen to his full interview here.

Qualified Registries have been combining data across sites and systems since their inception and have a track record of success with quality measurement for healthcare organizations.

At Mingle Health, we’re skilled at gathering data from multiple sources and providing consultative support along the way to train and engage ACO member practices.

EHR vs. Qualified Registry

Here are important capabilities to keep in mind when planning and evaluating the transition to the APM Performance Pathway (APP).

Capability EHR (eCQMs) Mingle Health (MIPS CQMs) Other Vendors (MIPS CQMs)
Dedicated advisor and consultant to guide you through the process ?
Aggregate data across EHRs & PM systems
Expert support navigating requirements that change annually and support after submission to CMS during a targeted review ?
Review data before it’s sent and submit the required format to CMS
Drill-down by practice, clinician, and patient-level to understand measure performance ?
Supplement EHR data for a more complete view of care delivery and quality ?

Start the transition now

Starting the transition now to the APM Performance Pathway (APP) will help you understand how your ACO will perform under the new methodology. You’ll likely opportunities for improvement and some common challenges with data consistency across sites and clinicians.

What questions do you have about the transition and eCQMs and MIPS CQMs? Get in touch here. Our team would be happy to learn more about your organization and provide a recommendation based on your systems.



2022 Final Rule and the End of Web Interface

Watch the webinar to learn about the transition to the APM Performance Pathway (APP) and MIPS CQM measures. We'll help you plan for success.

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