Physician Practice

Quality Measure Development Plan to replace PQRS, EHR Incentive Programs

Physician Practice Insider, December 29, 2015

On December 18, CMS published its draft Quality Measure Development Plan: Supporting the Transition to the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs). The Quality Measure Development Plan (MDP) paves the way for the agency’s move to Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APM).

The MDP will provide new quality measurement guidelines in support of these payment systems under the Medicare Access and Children’s Health Insurance Program Reauthorization Act of 2015. The MDP will replace current quality measures from the PQRS, EHR Incentive Programs, and Value-Based Payment Modifier. Some elements from these programs will be incorporated into the MDP, according to a CMS blog post.

The MDP focuses on problems and gaps in current quality measurements and suggests methods of improvement. CMS identified six categories it will include in future quality measurements:

  • Clinical care
  • Safety
  • Care coordination
  • Patient and caregiver experience
  • Population health and prevention
  • Efficiency and cost reduction

CMS acknowledged that, based on its experience developing and implementing quality measures, the agency expects to face several challenges. The MDP document lists each of them and details CMS’ plan for addressing them. Some of the expected pain points include:

  • Provider burden
  • Patient engagement in developing measures
  • Length of time for measure development
  • Creating measures that increase accountability across settings and providers
  • Creating meaningful outcome measures

CMS plans to reduce the burden of data collection and reporting on providers by eliminating redundancy, aligning measure sets across payers and settings, and by collecting data that is captured within the existing workflow.

Including patients or caregivers in the development process has been a challenge, CMS admits. It plans to improve this by working with patient engagement organizations as well as condition-specific patient organizations. CMS will also screen candidates to ensure they have experiences relevant to the measure development project.

New measures for MIPS will not be required to be submitted for consensus endorsement, but they must be evidence-based and published in a peer-reviewed journal before they can be used in MIPS. This could create a significant obstacle to moving new measures through development to implementation. The MDP requests suggestions and input on how to move proposed measures through peer-reviewed journals. Comments from peer-reviewed medical journals as well as developers are of particular interest to CMS on this matter. CMS plans to expand the use of its measure developers library and forums to help stakeholders share knowledge and work quickly and efficiently. Measure development time has already been shortened by the use of Lean principles, according to CMS.

The MDP was created to support the shift to MIPS, scheduled to take effect in 2019. MIPS calculates payment adjustments based on a total score aggregated from four categories:

  • Quality
  • Resource use
  • Clinical practice improvement
  • Meaningful use

The MDP will provide data used in the quality measurement. MIPS quality measures will be updated annually. Stakeholders will be able to submit new quality measures for consideration using the annual Call for Measures.

MDP scores will be published on Physician Compare.

The MDP draft plan is open for public comment until March 1, 2016. Final publication is scheduled for May 2016, and it will be updated May 2017 and May 2018 in preparation for the implementation of MIPS in January 2019.

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