CMS (Centers for Medicare and Medicaid Services) is the ultimate authority that serves as a guiding light for clinicians in America. QPP (Quality Payment Program) is one of its programs that is meant to streamline the clinicians’ financial matters through various sub-programs, such as MIPS reporting, APM reporting, ACO reporting, etc.
With time, these programs have undergone some changes in terms
of improving their outcomes or reducing the administrative load. For instance,
MIPS reporting that was in the year of its inception is different now. The same
goes for every other program.
Now, CMS aims to transform other QPP programs as well to
adopt the changing healthcare industry. Clinicians have many other things on
their plate, they also must cater to the administrative load. So, just
to be prepared in this regard, here is a brief description of what to expect in
the future in QPP.
The Introduction of MVPs
MIPS reporting is going to shift to a new reporting
framework, namely MVPs (MIPS Value Pathways). So, the traditional MIPS program
is going to revamp, and the new framework is going to work between MIPS 2023 to MIPS 2027.
What’s New in This Program?
MVPs are introduced to capture most measures of all four
categories into one measure set. For MIPS data submission, it brings together Quality, Cost,
Promoting Interoperability (PI), and Improvement Activities (IA), based on the
conditions.
To simplify this, CMS think tanks have categorized MVPs into
seven categories.
- Advancing
Care for Heart Disease
- Advancing
Rheumatology Patient Care
- Optimizing
Chronic Disease Management
- Improving
Care for Lower Extremity Joint Repair
- Support
of Positive Experiences with Anesthesia
- Adopting
Best Practices and Promoting Patient Safety within Emergency
Medicine
- Coordinating
Stroke Care to Promote Prevention and Cultivate Positive Outcomes
Based on the specialty and the reporting requirements of
MIPS 2023, eligible clinicians can participate in QPP MIPS.
The Introduction of APP (Alternative Payment Program)
Apart from the MVPs, there is another framework that CMS
wants to introduce, namely, APP (APM Performance Pathway). It will combine the
reporting efforts of MIPS Alternative Payment Models (APMs) and Accountable
Care Organizations (ACOs).
This framework allows eligible MIPS APM participants to
submit MIPS data via a pre-determined single measure set.
Moreover, Medicare Shared Savings Program (MSSP) ACOs has
the authority to submit data through CMS Web Interface in 2023. Having said
that, from 2025 onwards, all entities will have to submit data on three
eCQMs/MIPS CQMs!
The Introduction of FHIR and Digital Quality Measures (dQMs)
CMS wants to completely move to digital processes and systems
in the future. And they plan to do it via digital quality measures (dQMs) for
quality reporting. However, we can expect it to be done by the Fast Healthcare
Interoperability Resources (FHIR) in 2025.
What Is FHIR?
It is a free and open-source standard of frameworks for both
commercial and government settings. The purpose is to create a similar syntax
or protocol for all health IT by Health Level Seven International (HL7®). In
this QPP reporting framework,
there would be a common language to communicate easily throughout the systems
without any extra load.
Advancement in this framework is the integration of
application programming interfaces (APIs). In simple words, CMS wants to make
healthcare reporting easy for eligible clinicians through digital measures.
Ultimately, we can expect lower cost expenses and an interoperable health IT
infrastructure where all stakeholders can align their requirements with
technology.
Moving forward, the 21st Century Cures Act by ONC (Office of
the National Coordinator for Health Information Technology) created a
Standardized API. This API is for the Patient and Population Services
certification criterion for health IT.
Eligible clinicians while MIPS reporting or participating in
other quality payment programs would have to comply with one more rule. So, the
health IT developers require to update their health IT certificates as well.
And this has to be done by December 31, 2022, to support the United States Core
Data for Interoperability (USCDI) standard.
What Is the Use of APIs?
The reporting quality standard will improve significantly.
As we know, today, combining different health IT systems is troublesome and
moving data across EHRs requires much effort.
So, health IT developers have to align their data as per the
FHIR standard for:
- Quality
measurement
- Care
coordination
- Clinical
decision support
- Patient
access
List of Major Implications for a Digital Quality Reporting
Here is the list.
- Advancing
standards for digital data
- Collection
of all EHR Data required for Quality Measures via provider FHIR-based APIs
- Redesigning
quality measures to be Self-Contained tools
- Building
a pathway to data aggregation to support quality reporting
- Potential future alignment of measures for all reporting programs
Certified electronic health record technology (CEHRT)
provides the required technological capability, functionality, and security to
healthcare facilities. It assists them in meeting the meaningful use criteria
set by CMS. As per the 2020 rule, CMS allows clinicians to employ only
certified electronic health record technology (CEHRT) that complies with
certification standards. The Cures
edition update's requirements must be met by December 31, 2022, for an EHR to
maintain certification. This means that by the start of your 90-day PI
performance period in 2023, you must be utilizing an EHR with Cures Update
features. By the end of the performance period, your EHR has to be certified to
the 2015 Edition Cures Update.
Conclusion
As a clinician, there is a lot that you should cater to in
order to receive payment incentives. However, one should be updated with all
the changes that QPP reporting offers over time. The idea is to ensure the
accuracy of the program to maximize performance and unleash the payment
incentives.
Read more: Bird’s-Eye View of Final Medicare Physician Fee Schedule 2021