A Step-By-Step Checklist to Succeed with CMS’ APM Performance Pathway (APP)
The Centers for Medicaid and Medicare Services (CMS) programs are changing, in many ways for the better. If you are a Medicare Shared Savings Program Accountable Care Organizations (MSSP ACOs) or a Merit-based Incentive Payment System (MIPS) eligible clinician that participates in a MIPS APMs, you have likely heard of the changes as part of the new Alternative Payment Model (APM) Performance Pathway (APP).
In a previous blog, we explained in detail how MSSP ACOs will now be required to report 3 electronic clinical quality measures (eCQMs) via a CMS Qualified Registry or an Electronic Health Record System as part of program changes and the decommissioning of the CMS Web Interface. The three big benefits of reporting through the APP are:
- You report 3 measures, rather than 10.
- It counts as your improvement activity for the year, so you automatically receive 100% points for this performance category.
- The cost category is weighted at 0% as this aspect is built into your APM contract.
The only downside is that with change comes planning, preparation, and work. At the risk of suggesting one best way, we have identified five steps that will help you be successful with your transition to the APP.
Step 1: Review the measures that you must report
To start your alignment to the APP, review the pre-determined set of measures. The full measure set includes six measures, but only three of which you are responsible for reporting as the others are calculated off administrative claims or survey data. The below table identifies the three measures you are required to actively report, as well as how you are to collect and submit your data to CMS.
You should consider how – and how well – these measures are implemented within your organization today. Some elements to think about:
- How do these quality measures align to our organization’s annual goals?
- What leader(s) are responsible for the performance of these measures?
- How well do our providers and frontline clinicians understand our current performance?
- What, if any, historical change efforts have been made to address these outcomes?
Step 2: Evaluate how you will collect the data
In the APP, MSSP ACOs are required to actively report quality data on the three above quality measures. Accordingly, it is important to evaluate how you plan to collect the data elements required of each measure.
If you plan to do it manually, who are the team members and what role will each play in successfully extracting the data from the original system? If you plan to do it electronically, does your technology partner have the necessary capabilities to import and aggregate the data to your unique documentation workflows? Don’t forget to consider how the collection type will impact your resources because while measures can be collected multiple ways, each type has its own instructions and specifications.
Step 3: Discuss how you will calculate the measures
How will your organization assure the accuracy of your calculated performance rates? From the table above, you can see how the APP is evolving to eCQMs as a collection type. With annual changes to the measures specifications (things like updated value sets and changes with Quality Data Model attributes), it can quickly become burdensome to try to keep up with these changes. Using a NCQA eCQM certified partner, like KPI Ninja, that has proven the ability to implement logic to accurately calculate rates can alleviate the burden of keeping up with fast-evolving specifications to calculate performance rates. Don’t forget that if you plan to submit eCQMs, you need to use Certified Electronic Health Record Technology (CEHRT) that meets 2015 or 2015 Cures Update criteria to collect the data.
Step 4: Consider how you will use the data to improve performance
Reporting quality measures is only the first and most superficial aspect of successful quality efforts. You should be considering what data different team members need and at what level of frequency to be successful with improvement efforts. An example may be how a healthcare leader may only need quarterly performance reports, whereas a care manager may benefit from a weekly scorecard, care gap reports, and analytics. Your internal plan, as well as your technology solutions, should support your need to comprehensively use the data to not only report, but to guide improvement efforts, like how a KPI Ninja client in this case study measurably improved their performance with year-round quality analytics.
Step 5: Identify how you will report performance to CMS
There are two major elements you need to think about when you consider how you will report your performance to CMS. The first is the submitter type – or how you plan to interface with CMS. As CMS is decommissioning the Web Interface at the start of 2022, MSSP ACOs have the option of reporting the quality measures via a third-party intermediary – a CMS Qualified Registry or an Electronic Health Record that has direct, established connections to CMS – like a technology partner that has a computer-to-computer interface (like an Application Programming Interface (API)) to report on your behalf.
The second thing to keep in mind is how you will generate the required file format of the measures. With eCQMs being the next evolution of quality measurement and QRDA file formats as the output of eCQMs, you need a technology partner that can generate these files to standard, as like measure specifics, the QRDA Implementation Guides get updated every year.
In the recently updated toolkit materials, CMS encouraged ACOs to consider how they plan to aggregate and/or deduplicate the data. Finding a partner, like KPI Ninja that has deep experience with data transformation and normalization as well as generating QRDA files to industry standard, can help you successfully meet program requirements.
Evolving your measurement processes can be time-intensive, but they are incredibly useful to you as a health care leader to monitor, report and improve performance. By understanding program requirements and organizing the proper resources, successfully reporting through CMS’ new APP is not only possible but highly probable.
About the Author
Director of Quality Programs at KPI Ninja, Inc.
Renee provides operational leadership of quality initiatives at KPI Ninja. Towne has a background in occupational therapy, education and experience in operational excellence across a variety of healthcare domains. Based on prior experience as a clinician that drove outcomes patient by patient, she is leaving a larger footprint by improving health care more comprehensively, population by population.
About KPI Ninja
KPI Ninja is a data analytics company that helps healthcare organizations accelerate their quality, safety, and financial goals with a unique combination of software and service. We are differentiated by our signature mix of technology, performance management consulting and healthcare expertise. We don’t merely offer software solutions but work shoulder to shoulder with clients to help them draw on the power of analytics and continuous improvement methodologies to become more efficient. In harmony with our data-centered ethos, we truly believe that our success is strongly co-related with yours.