Citing rushed implementation, unanswered questions and potential negative consequences to patient care, 11 healthcare organizations are calling on the Biden administration to delay and make changes to mandated quality measure reporting for accountable care organizations.
The healthcare organizations, including the American Hospital Association and the American Medical Association, sent a letter to Department of Health and Human Services Secretary Xavier Becerra asking for a delay or other options.
The ACO Coalition has sent a separate letter to Becerra citing its concerns.
The concern regards changes to quality reporting for the Medicare Shared Savings Program published in the Final 2021 Medicare Physician Fee Schedule Rule.
The changes are scheduled to take effect this year and next, with the most notable being mandated in 2022.
WHY THIS MATTERS
The issue is that ACOs are a collection of hospitals and physician practices that do not necessarily use the same electronic health system. ACOs in the Medicare Shared Savings Program are being asked to aggregate data from disparate electronic health records systems, which are not interoperable.
The reporting requirements in the final rule are unrelated to interoperability mandates set by the Office of the National Coordinator or the Centers for Medicare and Medicaid Services. The ONC's work to create interoperability standards doesn't extend to quality measure aggregation and reporting.
The most realistic scenario for creating a system to extract and collect data from different EHRs would be to invest in a data vendor solution. It's an investment that 37% of ACOs responding to a National Association of ACOs report said would cost up to $499,000.
Also, ACOs are being required to report quality data on all patients, regardless of payer, raising issues with collecting data from non-ACO providers and on patients with no connection to the ACO.
The letter writers are concerned that if changes are not made soon, ACOs and their participants will bear significant health information technology costs and may drop clinicians -– particularly specialists or small practices – because of additional reporting burdens and IT costs, or could drop out of the program altogether.
"The changes ignore the time it takes to adopt and implement electronic measures," the letter states. "Therefore, key policy changes and additional time are needed to ensure that ACOs can participate successfully, and that patient care is not negatively impacted."
The letter makes several recommendations, based on input from ACOs, including: delaying the mandatory reporting for at least three years; limiting ACO reporting to ACO-assigned beneficiaries only, rather than all patients across payers; reassessing the appropriateness of the measures included in the Alternative Payment Model Performance Pathway measure set and soliciting additional input prior on a complete set of measures for MSSP reporting; clarifying and establishing quality performance benchmarks in advance for all ACO reporting options; and retaining pay-for-reporting when measures are newly introduced or modified.
"To start 2021, 477 ACOs are participating in the MSSP, down from a high of 561 in 2018 and the lowest since 480 participated in 2017," the letter stated. "The program is further threatened by these quality changes. We request CMS correct the flawed MSSP quality overhaul as an early step towards strengthening the MSSP and the overall shift to value in Medicare."
The letter was signed by the American Academy of Family Physicians, American College of Physicians, American Hospital Association, American Medical Association, AMGA, America's Essential Hospitals, America's Physician Groups, Association of American Medical Colleges, Federation of American Hospitals, Medical Group Management Association and the National Association of ACOs.
THE LARGER TREND
The Centers for Medicare and Medicaid Services released the 2021 Medicare Physician Fee Schedule and the rule finalizing the move to electronic quality measures in December 2020.
The rule requires the implementation of electronic Clinical Quality Measures or Merit-based Incentive Payment System clinical quality measures in 2022.
ON THE RECORD
Clif Gaus, president and CEO of the National Association of ACOs, said "In the middle of global pandemic, it seems outrageous for CMS to require these changes that have questionable clinical benefit and cost hundreds of thousands of dollars per ACO. CMS is naïve to think the state of EHRs today allow these quality data to be easily compiled."
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