NAACOS Calls on CMS to Adjust Digital Quality Measurement Requirements

Before implementing program-wide requirements for digital quality measurement in the Medicare Shared Savings Program (MSSP), CMS should establish a pilot that tests the technical feasibility and the impact on accountable care organizations (ACOs), according to the National Association of ACOs (NAACOS).

Starting in 2025, MSSP ACOs must use electronic clinical quality measures (eCQMs) and digital quality measures (dQMs) for quality reporting. However, this may pose a challenge for ACOs as they can include multiple doctor’s offices, hospitals, and practices that do not use the same EHR system.

The NAACOS Digital Quality Measurement Task Force issued a position paper calling on CMS to consider several recommendations before establishing eCQMs within the MSSP.

“Numerous thought leaders from across a broad swath of ACOs spent months deliberating this issue to develop thoughtful, commonsense recommendations to move our industry to digital quality reporting,” Katherine Schneider, MD, chair of the NAACOS Digital Quality Measurement Task Force and past NAACOS board chair, said in the press release.

“ACOs simply cannot report quality data as easily as a single, standalone health system or physician practice. Different considerations need to be made. NAACOS absolutely supports the need to move to a more digital and less manual form of quality reporting, but more work needs to be done by both government regulators and the health IT industry before this becomes widely possible for ACOs.”

The task force urged CMS to work with ACOs and create a pilot that tests the reporting of quality data received from EHRs before making the requirement a program-wide mandate.

Additionally, NAACOS asked CMS to remove the current requirement for ACOs to report data on all patients from all payers. According to NAACOS, this would hurt ACOs serving vulnerable populations because they would be assessed on the composition of the ACO and its payer mix rather than on the clinical quality of care.

These penalties may disenfranchise safety-net providers and force ACOs serving sicker patients to exit the program or limit ACO participant practice, the position paper stated.

AS CMS and the Office of the National Coordinator for Health IT (ONC) consider the future of digital quality measurement, they should aim to improve how quality data can be captured to better support patients at the point of care and reward high-value care.

The current state of data standards and interoperability will not allow ACOs to meet all of the eCQM reporting requirements. According to NAACOS data, 39 percent of ACOs have more than ten EHRs and only 17 percent have one EHR. Many ACOs rely on third-party companies to help aggregate data, increasing costs. Thus, EHR certification criteria must support ACOs in eCQM and dQM reporting.

NAACOS said CMS should provide policy incentives to help offset the initial and ongoing costs associated with transitioning to eCQMs and dQMs, such as making clinical quality measures pay-for-reporting and or ensuring shared savings are not at risk.

The organization also recommended that CMS identify an alternative pathway to transmit data in a standardized way to enable successful patient matching, such as national patient identifiers. The agency should also standardize data to assist in data mapping and other workflow changes needed to transition to eCQMs and dQMs.

In September 2022, NAACOS, the American Medical Association (AMA), and other healthcare groups urged CMS to make additional MSSP-related changes before finalizing the 2023 Physician Fee Schedule. For example, the groups asked the agency to expand eligibility for advanced investment payments to all ACOs working to improve health equity. They also requested that CMS remove the all-payer requirement for eCQM reporting.