Medical Groups Ask for More Time Before ACO Quality Reporting Changes

According to nearly a dozen leading medical groups, changes to accountable care organization (ACO) quality reporting are rushed, unclear, and potentially harmful to patient care.

In a letter to HHS Secretary Xavier Becerra earlier this month, the groups asked for more time before implementing the changes to the Medicare Shared Savings Program (MSSP) finalized in a rule published last year. The changes include reducing the number of quality measures ACOs in the MSSP report on and moving to more electronic data sources for ACO quality reporting.

“The changes ignore the time it takes to adopt and implement electronic measures,” the letter stated. “Therefore, key policy changes and additional time are needed to ensure that ACOs can participate successfully, and that patient care is not negatively impacted.”

Among those signing the letter was the American Medical Association (AMA), American Hospital Association (AHA), AMGA, and National Association of ACOs (NAACOS).

ACO quality reporting is central to the alternative payment and care delivery model. Quality performance not only ensures high-quality patient care but also determines an ACO’s reimbursement since participants must meet quality performance standards in order to be eligible for shared savings payments.

HHS decided to overhaul ACO quality reporting in the MSSP to align requirements with those under the new Alternative Payment Model Performance Pathway (APP) under the Quality Payment Program since participating ACOs will have to report quality data via the APP moving forward as part of the program’s Advanced APM track.

“We believe working towards a future state of the program that is more aligned through these reporting pathways will achieve our goal of moving away from siloed performance category activities and measures and moving towards sets of measurement options that are more relevant to a clinician’s scope of practice and that are meaningful to patient care,” HHS said in a fact sheet on the ACO quality reporting changes last year.

The medical groups, however, said the changes “lacked adequate input from the patient, ACO, physician and hospital communities” and it still remains unclear as to how HHS’ agencies determined APP measures were more appropriate for ACO quality reporting.

“Quality measurement within the MSSP must focus on measures most appropriate to the program,” they wrote in the letter. New measures, for example, may be “especially sensitive to differences in clinical complexity and social risk factors across patient populations,” they argued.

“Evaluating quality of care protects against the possibility of stinting on care which can be a concern when determining accountability for costs,” the letter stated. “We believe there is an important opportunity for CMS to revise aspects of the recently finalized MSSP policies to better support ACOs and promote high quality patient care.”

The groups suggested that HHS reassess the appropriateness of APP measures and solicit additional feedback from the healthcare community. Additionally, the grouds advised HHS to limit ACO quality reporting to just beneficiaries assigned to the ACO, clarify and establish quality performance benchmarks for all ACO reporting options, retain pay-for-reporting for new measures, and delay implementation of mandatory reporting of electronic clinical quality measures (eCQMs) for at least three years.

A recent survey fielded by NAACOS found nearly all MSSP ACO respondents were concerned about the implementation of eCQMs in 2022, with nearly 75 percent describing themselves as “extremely concerned” or “very concerned.”

Failing to delay implementation considering such high levels of concern with the ACO quality reporting changes could undermine the MSSP, the groups contended.

"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 program is further threatened by these quality changes," the letter stated. "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."