Eleven major healthcare organizations have called on the Biden administration to make significant changes in the way Medicare Shared Care Program (MSSP) responsible care organizations (ACOs) report and measure quality. .
In a letter dated May 4th to the Secretary of Health and Human Services Xavier Becerra, the doctor, the hospital and the organizations of the ACO, said that the new regulations finalized in December were precipitated without the sufficient participation of the interested parties and that they supposed a significant load for ACOs that could cause some to leave the program.
The new Centers for Medicare and Medicaid Services (CMS) rules, which will go into effect this year and next, are included in the Medicare Physician Physician 2021 rate. To begin with, they require participating organizations to move from reporting to through a CMS website to a new electronic information system.
According to one press release from the National ACO Association, organizations will need to “aggregate data from disparate, non-interoperable electronic health record systems, and report on quality data from all patients regardless of payer, posing problems with the collection of data from non-ACO providers and on patients not connected to the ACO “.
The current reporting system requires ACOs to report only in a sample of your attributed Medicare beneficiaries.
The requirement of all payers of the new rules could distort the quality of ACOs, among other issues, the coalition argued. “ACOs that treat vulnerable populations have a different mix of patients and taxpayers, which will make them look low quality,” the letter said. “This will reduce their shared savings while they should receive more resources to combat health equity issues and more support to continue on the path to value.”
In a recent survey, nearly 75% of respondents said their ACO is “extremely concerned” or “very concerned” about the requirement to implement new electronic clinical quality measures or incentive-based payment system measures. on merit (MIPS) in 2022. In addition, 85% of ACOs who responded said that adding data on all patients from the disparate electronic registration systems of their participants would be “difficult” or “very difficult”.
Changes in the MSSP quality reporting methodology are of concern to a large part of the healthcare industry. Among the organizations that signed the letter to Becerra, in addition to NAACOS, are the American Academy of Family Physicians, the American College of Physicians, the American Hospital Association, the American Medical Association, the American Medical Group Association, America’s Essential Hospitals, American’s Physician, The Association of American Medical Colleges, the Federation of American Hospitals, and the Medical Group Management Association.
Recommendations to CMS
The coalition’s letter makes several recommendations and explains the reasons for each of them.
First, the coalition calls on CMS to delay mandatory notification of clinical quality measures, which is scheduled to begin in 2022, for at least 3 years. Most ACOs have many different electronic health record systems; in fact, nearly 40 percent of ACOs include more than 15 systems, the letter says. The integration of quality data from all of these systems will require ACOs and their members to assume significant system costs and upgrades and increase their data collection loads.
ACOs must fund this work in advance, long before they can receive shared savings from the program, and to date, only 35% of ACOs have obtained any shared savings from the program. If they have to sharply increase their overhead to meet these requirements, many ACOs may leave the program or never join, the coalition said.
The CMS should also limit quality reporting to assigned Medicare beneficiaries, the coalition said. One reason is that data access limitations make it difficult to extend data to all payers. The new rules require ACOs to report on 70% of all patients cared for by their members, a “huge increase” compared to the small sample [of Medicare patients] required in the web interface, “the letter noted.
In addition, it is unclear whether ACOs have the contractual or legal right to collect data on patients who are not covered by traditional Medicare. “It will be extremely difficult, if not impossible, due to the availability of data and possible violations of Stark or HIPAA laws, for ACOs to monitor patients and their care when they are not directly related to the ACO. “, said the letter.
The quality of ACOs could also not be fairly represented, the coalition stressed, if the measure includes vulnerable populations that ACOs do not care for and who have significant problems related to the social determinants of health.
“As a result of these many concerns and the potential impact on data integrity, we believe that expanding the data of all payers for ACOs is not appropriate,” the letter said. “This change dramatically increases the complexity of the program, which is not of interest to Medicare, CMS, or ACO beneficiaries. In addition, the resulting quality performance scores will not represent the quality of care provided by an ACO and will also make CMS more difficult. ability to assess the impact of ACO interventions on the quality of care for patients cared for. “
Set of quality measures
The letter also stated that CMS had changed the established quality measure without obtaining the appropriate input from stakeholders. Decreasing the number of metrics is welcome, the coalition said, but “the current set is too narrow and not patient-centered.” Most of the measures focus on primary care services and cannot be used to measure specialist care, the coalition said.
The coalition also protested the use of MIPS quality performance parameters to assess ACO performance. Because these criteria will apply to all patients, not just Medicare beneficiaries, they will be unfair to some groups because of differences in access, insurance coverage, medical complexity, and other factors, depending on the letter.
Finally, the coalition said CMS should restore the ability to pay new ACOs to get quality reports for a year, without the results being applied to their shared savings. This “pay-for-reporting” feature is critical to the success of the ACO, as it provides the ACOs with time to evaluate their workflows, data capture processes, etc., before they are classified into the data. , points out the letter.
CMS did not comment on the letter at press time.