ACOs Call on ONC, EHR Vendors for CMS eCQM Reporting Support

The Centers for Medicare and Medicaid Services (CMS) has made it a goal to move to electronic clinical quality measures (eCQM) by 2025. However, accountable care organizations (ACOs) often work with multiple EHR vendors and systems, which means they need makes eCQM reporting support.

A NAACOS survey found that more than half of ACOs said they would not be ready or were unsure if they would be prepared to report eCQMs by 2025.

"This is just not on radar sufficiently yet, and it really needs to be," Katherine Schneider, MD, chair of the NAACOS Digital Quality Measurement Task Force, said during a roundtable discussion at the fall 2022 NAACOS Conference.

Particularly, cost is top-of-mind for ACOs worried about upcoming eCQM requirements.

Schneider noted that two-thirds of ACOs that answered a survey question about cost said that the price for yearly eCQM data aggregation services from a third party would be upwards of half a million dollars.

Megan Reyna, system VP of practice transformation and quality improvement at Advocate Aurora Health, which operates two ACOs, said she gets over a million dollars from vendors for eCQM data aggregation services.

This large price tag is standing in the way of many ACOs adopting eCQMs.

"ACOs don't have an EMR," Reyna pointed out, indicating it’s not a single health IT platform that supports the whole of the ACO.

"The participants of the ACO have an EMR, so it just makes the conversation a little bit more complex. Not saying that we don't want digital measurement," Reyna added. "We absolutely do, and we've been asking for it for ten years."

She emphasized that ACOs want to be able to leverage eCQMs to drive healthcare improvement, not just to fulfill CMS reporting requirements.

"We want digital measurement that isn't just about going to CMS, that's actually used for patient care and used for something that makes improvement," she said. "I am willing and capable of spending money on doing something that's going to move us along the technology journey."

Schneider said that while data governance falls on the ACOs, they need help from EHR vendors. The Digital Quality Measurement Task Force hopes that ONC will implement EHR certification requirements that support eCQM for CMS value-based care programs to help save healthcare organizations from spending resources on data aggregation, Schneider said.

Steven Posnack, MS, MHS, deputy national coordinator for health IT, noted that ONC could change its certification program, but it will take time.

"We have closely linked arms with our CMS colleagues, and we've adjusted our criteria over time to reference their implementation guides, reporting mechanisms, and capabilities," he said. "We have to go through a regulatory process. There also needs to be available standards and implementation guides to reference."

Even without current eCQM requirements for ONC-certified health IT, some EHR vendors are working on technology to help customers meet the eCQM reporting requirements.

Nick Frenzer, an implementation executive from Epic Systems, said that the EHR vendor is developing code to ingest QRDA1 reports (individual patient quality reports) to generate QRDA3 reports (aggregate quality measure data reports) so that ACOs don't require additional data aggregation software.

"We'll be releasing that code in the first half of 2023," Frenzer said. "Most groups upgrade their code six to nine months after we release it. During that timeframe, there'll need to be a discussion with all providers within your ACO to understand their capabilities of whether they can produce that QRDA1 or adapt to a FHIR standard."

ACOs are also concerned about the de-duplication of data for patient matching, which Epic is also working on.

"In an EHR, patient matching is patient safety," Frenzer added. "When we emerge a patient's record, we have to have high confidence that we're doing the right thing so that we don't make a clinical error."

He explained that by using four demographics for patient matching, which is the current standard, healthcare organizations must manually review 20 percent of patients coming into a system.

"A human needs to determine if that patient is a match or not," Frenzer said. "That's a significant time effort that needs to be reduced."

By adding a phone number and email to the demographics for patient matching, Epic reduced the manual review rate to just two percent for new patients coming into a system.

"There's a high opportunity for us to make this a standard for demographics so that we can safely do matching," he said. "By pushing that down to under two percent, the labor is significantly reduced. Our commitment is to make this as easy as possible to reduce the cost to our health systems and improve value-based care."

According to Doug Jacobs, MD, MPH, chief transformation officer for CMS, the agency is also looking to support the alignment of eCQMs across the value-based care continuum to streamline reporting requirements.

"From the provider's perspective, we have all these different value-based care arrangements with different quality measures," he said. "It's really challenging to figure out what to prioritize and how to advance population health with the folks you're treating. We're working across centers to make sure that these measures are similar and that the specs are similar."

He noted that CMS's new national quality strategy aims to create a universal set of quality metrics across value-based care programs. CMS is working on the plan with the Center for Clinical Standards and Quality (CCSQ).

"At its core, the strategy seeks to achieve optimal health and well-being for all persons by enabling the safest and most effective care for every individual," said Molly MacHarris, a senior policy advisor at CCSQ.

"It's important to ensure timely, secure, seamless communication and care coordination between providers, plans, payers, community organizations, and individuals through interoperable shared and standardized digital data across the care continuum," MacHarris added.

She emphasized that the transition to digital quality measures will help advance health data interoperability.

"We learned through the COVID-19 pandemic how essential it is to have available data, which can be pulled from multiple sources and sites of care to best support timely, actionable public health, clinical care, directing of resources, and public policy," she said.

"Digital quality measures can help accelerate the pathway for interoperable digital healthcare data," MacHarris concluded. "Additionally, digital quality measures allow for seamless data collection where data flows as an outcome of clinical processes."