Coalition of National Healthcare Associations Asks HHS to Delay New Quality Reporting Requirements
The leaders of a coalition of eleven prominent national healthcare associations on Monday, May 4 sent a letter to Secretary of Health and Human Services Xavier Becerra asking the Department of Health and Human Services (HHS) to delay the changes in the final 2021 Medicare Physician Fee Schedule Rule that were finalized in December, around quality reporting for accountable care organizations (ACOs). The associations involved told Secretary Becerra in their letter that the policies set to be implemented for ACOs participating in the Medicare Shared Savings Program (MSSP) need revision, and that the new measures created in the Alternative Payment Model Performance Pathways (APP) measure set from the Centers for Medicare and Medicaid Services (CMS) will end up being unfair to participating MSSP ACOs.
The letter, whose entire text is available here, addressed Secretary Becerra by name, and began thus: “Dear Secretary Becerra: The undersigned organizations write to express our increasing concerns with the recent changes to quality reporting for the Medicare Shared Savings Program (MSSP), which were finalized in the Final 2021 Medicare Physician Fee Schedule Rule (CMS-1734-P), as published in the Federal Register on December 28, 2020. Quality improvement is a cornerstone of the ACO model. In addition to reducing spending, ACOs must meet quality performance standards to be eligible to receive shared savings payments. ACOs continue to improve quality year over year, which improves patient care and helps to control costs. It is critical that policies to evaluate ACO quality are fair, appropriate and accurately reflect the work ACOs undertake to improve patient care.”
Indeed, the coalition’s members wrote, “While reducing the number of measures and leveraging electronic data sources for quality reporting are important goals, we have significant concerns about the MSSP quality policies finalized at the very end of 2020. The policy changes lacked adequate input from the patient, ACO, physician and hospital communities, and it is unclear how the Center for Medicare & Medicaid Services (CMS) determined that the Alternative Payment Model Performance Pathways (APP) measures are more appropriate than the current measures on which ACOs are evaluated. Quality measurement within the MSSP must focus on measures most appropriate to the program. Evaluating quality of care protects against the possibility of stinting on care which can be a concern when determining accountability for costs. We believe there is an important opportunity for CMS to revise aspects of the recently finalized MSSP policies to better support ACOs and promote high quality patient care.”
The concern, they wrote, is this: “The new MSSP measures may be especially sensitive to differences in clinical complexity and social risk factors across patient populations. Yet, CMS has not articulated how the agency will account for these differences, which is especially problematic since the data will be collected on an all-payer basis. This policy gap means that ACOs serving sicker and more vulnerable patients may score more poorly.”
The nine associations that are co-signatories to the letter are: the American Academy of Family Physicians; American College of Physicians; American Hospital Association; American Medical Association; AMGA (American Medical Group Association); America’s Essential Hospitals; America’s Physician Groups; Association of American Medical Colleges; Federation of American Hospitals; Medical Group Management Association; and National Association of ACOs.
The coalition’s leaders specifically asked Secretary Becerra to do the following things:
“1. Delay the mandatory reporting of electronic Clinical Quality Measures (eCQMs) and Merit-based Incentive Payment System Clinical Quality Measures (MIPS CQMs) for at least three years.
2. Limit ACO reporting to ACO assigned beneficiaries only, rather than all patients across payers.
3. Lower the data completeness requirements beginning at 40 percent with a gradual increase to a maximum of 50 percent for those reporting eCQMs or MIPS CQMs or explore alternative approaches.
4. Reassess the appropriateness of the measures included in the APM Performance Pathway (APP) measure set and solicit additional input through the Measures Application Partnership (MAP) prior to finalizing a complete set of patient-centered measures for MSSP reporting.
5. Clarify and establish quality performance benchmarks in advance for all ACO reporting options.
6. Retain pay-for-reporting when measures are newly introduced or modified.”
In the conclusion to their letter, the co-signatory associations wrote that “ACOs remain committed to providing the highest quality care and improving patient outcomes while also delivering this care in the most cost-efficient manner. To that end, we urge CMS to reconsider the decisions finalized in December 2020 and work with our organizations and ACOs to find alternative approaches and a different timeline that will meet CMS and ACO needs. We appreciate your consideration of these recommendations and welcome an opportunity to work with the agency to provide further feedback and to support ACOs and the transition to value,” they wrote.
