The Proposed Changes and Their Impact for ACOs under MSSP
Below are four key components to the recent CMS announcement that all ACOs should be aware of, as they prepare any potential comments for submission to CMS, which are due September 9, 2024.
1. Additional Quality Measures
CMS is driving alignment across its quality programs by introducing the APP Plus quality measure set. This new framework consolidates measures from the existing APP set with additional measures from the Adult Universal Foundation. By mandating the adoption of these measures, CMS aims to harmonize reporting across Medicaid Core Sets, the Marketplace Quality Rating System, and Medicare Advantage and Part D Star Ratings.
Under the proposed rule, the APP Plus set will expand to include eight measures in 2025 and eleven by 2028. This phased approach ensures that ACOs can gradually adapt to new reporting requirements while maintaining focus on improving patient outcomes and care delivery.
2. MIPS Clinical Quality Measures Eliminated
To simplify reporting and encourage the adoption of electronic Clinical Quality Measures (eCQMs), CMS proposes to streamline collection types for ACOs under MSSP. Moving forward, MIPS CQMs will phase out as a reporting option, emphasizing eCQMs and Medicare CQMs as the primary methods. This shift not only aligns with CMS’s Digital Quality Measurement (dQM) Strategic Roadmap, but it also aims to reduce operational complexities for participating ACOs.
It is anticipated that CMS may seek to eliminate the Medicare CQM option in future years as well, with an emphasis on eCQM submissions.
3. Additional Incentives for eCQMs in 2025
Recognizing the importance of digital interoperability, CMS plans to extend incentives for ACOs that fully adopt eCQMs within the APP Plus set. ACOs meeting data completeness requirements for all eCQMs will be eligible for enhanced shared savings under MSSP, reinforcing the agency’s commitment to promoting advanced quality measurement practices.
4. Complex Organization Adjustment
To address the unique challenges faced by virtual groups and APM Entities, CMS proposes a Complex Organization Adjustment starting in performance year 2025. This adjustment aims to fairly assess performance by awarding achievement points for each eCQM meeting specified criteria, thereby supporting organizational complexity without compromising quality assessment standards.
5. Scoring of Medicare CQMs
Medicare CQMs, available only to Shared Savings Program ACOs, would be scored using flat benchmarks for the measures’ first two performance periods, until historical data is available for establishing benchmarks. The use of flat benchmarks would allow ACOs with high scores to earn maximum or near maximum achievement points while allowing room for quality improvement and rewarding that improvement in subsequent years.
The Proposed Changes and Their Impact for Clinicians under Traditional MIPS/MVP
The Quality Payment Program also sees substantial changes:
1. Gradual Phase-Out of MIPS: CMS proposes to phase out MIPS and establish MVPs as the primary participation mode by 2029, with six new MVPs introduced for the 2025 performance year.
2. Updates to Quality Measures: The proposed 2025 quality measure inventory includes 196 measures, with new additions, removals, and substantive changes. The data completeness threshold remains at 75% for 2027 and 2028.
3. Improvement Activities: CMS proposes to remove activity weightings and reduce the required number of activities to report, which would simplify scoring and decrease burden.
4. Promoting Interoperability: Changes in this category include the removal of automatic reweighting for clinical social workers and detailed criteria for qualifying data submissions. For multiple data submissions in this category, CMS would calculate a score for each data submission received, and assign the highest of those scores. Previously, multiple submissions would result in a score of zero.
Why These Changes Are Important
Unified Reporting and Improved Patient Outcomes
For ACOs, the integration of the APP Plus quality measure set and the emphasis on eCQMs streamline reporting processes and foster uniformity across CMS programs. This alignment not only reduces administrative burdens but also drives improvements in patient outcomes by focusing on comprehensive, high-quality care.
Transitioning to MVPs
For clinicians, the shift from MIPS to MVPs represents a move towards more specialized, outcome-focused reporting. This transition is designed to enhance the quality of care while maintaining flexibility and reducing reporting complexity.
Support for Regulatory Changes
MRO is committed to supporting both ACOs and clinicians through these transitions:
1. ACO Performance Pathway: Helps ACOs adapt to new reporting requirements, optimize performance, and maximize shared savings. We provide tools for data collection, measure computation, and performance monitoring, ensuring seamless compliance with the APP Plus set
2. MVP Module for Clinicians: The MVP module offers advanced features to help clinicians navigate the shift from MIPS to MVPs. By incorporating regulatory changes into our dashboard, clinicians can track their estimated scores and estimated Composite Score in real time, ensuring they meet compliance standards, avoid penalties and earn incentives.
3. Training and Support: MRO offers training and support to help organizations understand and implement these changes effectively. Our experts guide you through the nuances of new measures and reporting processes, ensuring a smooth transition and continued success
Looking Ahead
The proposed changes by CMS for both MSSP ACOs and traditional MIPS/MVP participants signify a transformative shift in healthcare quality reporting. By understanding and adapting to these updates, healthcare providers can enhance care delivery and achieve better financial outcomes. MRO continues to stay informed of the ongoing changes to reporting requirements and can help support organizations no matter the size or complexity of their network. MRO’s commitment is to ease the burden of quality reporting and assist in maximizing performance. To learn more about ACO PerformancePathway, click here and to learn more about Registry PerformancePathway, click here.
The above blog post contains research and contextual conclusions provided by Ranu Ray, CMS Research Business Analyst.
