The Medicare Shared Saving Program was made available to all healthcare providers and hospitals on July 1, 2012. The motto behind their establishment was more or less the same as it is for MIPS, APPs, or MVPs. The Centers for Medicare and Medicaid Services just wanted to reduce healthcare expenditures to as much as possible. On the other side, CMS was determined not to put the population’s health betterment at stake by any chance. Therefore, the Shared Saving Program asked all related healthcare professionals to make their Accountable Care Organizations. Furthermore, ACO reporting options open up ways for all ACO Medicare to extract the maximum benefit from the provided opportunity.
Here in this blog, We especially discuss the replacement of the ACO reporting collection type with two new ones. And what will be the effective ACO quality measures reporting procedure from now on?
Sunset of CMS Web Interface for MIPS Program
The Physician Fee Schedule for PY 2021 authorized all the Medicare Shared Savings Program ACOs to take part in APP. Here, APP (APM Performance Pathway) is one of the two reporting frameworks of the Quality Payment Program. The APM Performance Pathway mainly gives them the privilege of ACO reporting following a specified measure set. As we know, we have various collection types for reporting and submitting quality measures to CMS. An entity may choose one or different collections for its measure reporting considering their ease. Thus, the APM pathway has required the;
- 10 measures are reported via the CMS Web interface;
- Or 3 measures via MIPS CQM collection type / eCQM collection types.
Things were going very smoothly by this directed passage. But to overcome some issues, the Physician Fee Schedule Final Rule for PY 2022 came with a big surprise. As per the finalized policies, CMS announced the closure of CMS Web Interface as a collection type for Traditional MIPS. Anyhow, the type of collection is still accessible for ACO reporting via the APP. Thus, CMS Web Interface will be closed for sure after PY 2024.
New Collection Types for ACO Quality Measure Reporting
Alongside CMS Web Interface, there were two other collection types for ACO reporting at our disposal. Beginning from PY 2025, these two collection types will be the only option for every Commercial ACO. Anyhow, we are again mentioning these two collection types here for your ease.
- MIPS Clinical Quality Measure (CQM)
- Electronic Clinical Quality Measure (eCQM)
The Quality Reporting Process for ACOs
The Medicare Accountable Organizations intentionally consider the risk responsibility. However, they practice eliminating all the related risks with the best of their performance and excellent strategies. But we know nothing comes easy when you start acting on your destination plan. So, ACOs have encountered similar scenarios in ACO reporting via the APP. The entities in an Accountable Care Organization faced problems in assembling, eradicating duplications, and aligning all patient data. These ACO reporting difficulties have the major input from the eCQM and MIPS CQM collection types.
But CMS aims not to take an effect on what happened in the past, or influence the things planned to do in the future. Considering these problematic situations, one must have clarity about the ACO quality reporting process in detail. This approach will help them to act accordingly to their course of action during the reporting period. CMS has not left ACOs empty-handed as it has provided comprehensive guidelines to follow. It has structured a firm framework for accomplishing ACO reporting standard goals. Let’s overview the ACO quality reporting process here.
Check out the Population Eligibility for the ACO Quality Measures
Firstly, every Accountable Care Organization must identify the data sources that are accessible. Only then can complete their ACO reporting across the whole patient population of ACO members.
Secondly, ACO Medicare has a huge responsibility of choosing the collection type for each measure. Therefore, they must be wise enough while make this decision. ACOs must go for the collection type that is more suited for each measure. Afterward, they will obtain patient-level information for each participant’s TIN and CCN per the measure’s requirements.
Patient Data screening and aggregation for ACO Reporting
Then, ACOs must collect all patient data. Make sure the data enables patient matching and deduplication to the extent required for the delivery of valid and dependable quality measures. Also, they necessarily uphold organizational guidelines that detail the ACO’s strategy for patient identification and aggregation. The matched, deduplicated population will be completely reflected in the eligible population analyzed for quality assessment.
Application of Measure Logic and Data Completeness Requirements
ACOs have to consider the measure logic for applicable specifications accordingly. For this, they ensure that;
- the eligible population that satisfies the denominator requirements, and
- the numerator results and any suitable exclusions and/or exceptions.
Then, consider the data completeness requirement identified for MIPS CQMs as given below:
Performance Year | Data Completeness Requirements for MIPS CQMs (% of eligible and matched denominator population) |
2022 | 70% |
2023 | 70% |
2024 | 75% |
2025 | 75% |
Note: The eCQM collection type automatically satisfies the data completeness criteria when data are collected using certified electronic health record (EHR) technology (CEHRT).
ACO Reporting to CMS
ACOs must adopt appropriate forms when submitting measure performance to CMS. Based on the data you have provided; CMS will determine performance rates and data completeness. For the measure(s) provided, each submission should be deemed complete. If necessary, ACOs may submit findings again throughout the reporting period; however, any subsequent submissions take precedence over earlier ones. ACOs are advised to provide data as soon as possible throughout the reporting period to save time for fixing any technological problems.
Conclusion
In short, ACO reporting via APP requires the related entities to set their planning beforehand. It will help them to gather and report data for quality performance in the best possible way. The Medicare Shared Saving Program ACOs must give attention to its particular structure and needs while choosing its quality measures.