As Senior Editor Rajiv Leventhal reported on Dec. 22, late this month, the federal Centers for Medicare & Medicaid Services (CMS) released a Quality Measure Development Plan (MDP) to serve as a strategic framework for the measures to be incluced in the new Merit-based Incentive Payment Program and alternative payment models (APMs) for physicians under the Medicare program.
As Rajiv noted, “In addition to repealing the long-maligned sustainable growth rate (SGR) formula for Medicare physician payment, the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), signed into law earlier this year, ends physician payment incentives under the meaningful use program within the HITECH (Health Information Technology for Economic and Clinical Health) Act, and those under the Physician Quality Reporting System (PQRS), replacing the incentives in those programs with a new program called the Merit-based Incentive Payment Program, or MIPS. Physicians will also be able to opt for an alternative program involving slightly higher payments in return for participation in certain alternative payment models, or APMs.”
CMS is now accepting comments from the industry through March 1, 2016, with the final MDP to be revealed on the cms.gov website by May 1.
As I noted in my April 14 report on the legislation that had just been passed by Congress creating the new program, “The legislation will replace physicians’ mandatory participation in the Value-Based Payment Program under Medicare (for all physicians participating in Medicare) with a new Merit-based Incentive Payment System, or “MIPS.” Under the new “MIPS,” to be applied to payments beginning Jan. 1, 2019, the Secretary of Health and Human Services would “assess appropriate adjustments to quality measures, resource use measures, and other measures used under the MIPS; and… assess and implement appropriate adjustments to payment adjustments, composite performance scores, scores for performance categories, or scores for measures or activities under the MIPS.” And, I added, “The legislation targets four key areas: quality, resource use, clinical practice improvement (including care coordination and improvement activities), and the meaningful use of certified EHR (electronic health record) technology.”
Much of this new document is a broad statement of aspiration, with the bulk of it devoted to strategic principles and affirmation of the need for all stakeholder groups to be involved in the preparation of the measures to come.
A couple of important excerpts from the Quality Measure Development Plan (MDP) itself:
“MACRA identifies five quality domains (i.e., clinical care, safety, care coordination, patient and caregiver experience, population health and prevention) for measures developed under the MDP, which align with the National Quality Strategy and the CMS Quality Strategy. CMS is also taking into consideration the quality domain of efficiency and cost reduction… CMS will collaborate with specialty groups and associations to develop measures that are important to both patients and providers and that represent important performance gaps in the targeted quality domains. When consider measures, CMS will prioritize outcomes, person and caregiver experience, communication and care coordination, and appropriate use/resource use.”
Among other key points:
- “No clinical practice improvement activities have yet been established under MIPS. In updates to the MDP, CMS will evaluate clinical practice improvement activities to identify concepts that could result in innovative approaches to new measure development at the national level to address gaps in measurement and clinical care.”
- “CMS prioritizes electronic clinical quality measure (eCQM) development in a manner that ensures relevance to patients and the public, improves measure quality, increases clinical data availability, accelerates development cycle times, and drives innovation.”
There is a great deal of detail around the framing of the five key domains—clinical care, safety, care coordination, patient and caregiver experience, population health and prevention—for the measures to be developed under the MDP.
For example, in the clinical care area, the document states that “CMS will collaborate with specialty groups and associations to develop measures where there are important gaps in performance and for topics that are important to both patients and providers. Outcome measures (including PROMs and measures of functional status), intermediate outcome measures, and measures assessing diagnostic skills and adherence to clinical practice guidelines are measure development priorits for MIPS and APMs. We solicit comments and suggestions for development of measures in this domain.” The same kinds of statements are made in the other four areas—safety, care coordination, patient and caregiver experience, and population health and prevention.
Alas, there are no crunchy details revealing the specifics of what CMS officials actually believe should be in the new measures. Perhaps I was deluded in thinking that such specifics would be in this draft document. In any case, the only conclusion I can come to about that is that there is a real opportunity here for provider leaders—clinicians, clinician leaders, clinical informaticists, other informaticists, and all the associations for all those stakeholder groups—to truly help CMS officials shape this new thing.
The fact is, this new set of measures is going to be immensely important, as, in a practical sense, it will help drive physician clinical performance in the coming decade.
Of course, associations are going to leap into this void, and that is good. But I would say that those medical group and hospital leaders from across disciplines—primary care and specialist physicians, nurses, medical and nurse informaticists, and even non-clinical informaticists—have real skin in this game, as do the non-clinician leaders of medical groups and hospitals (even though these measures will largely be ambulatory in nature, they will absolutely have ripple effects on hospital care management).
So 2016 could really be a year of opportunity for stakeholders here. The one thing that no one should be under any illusion about is the fact that these measures in this new MIPS system are going to be important. They are going to be very important; they will determine how many physicians are paid under Medicare, which means that there’s no question they will also be adopted in some form by private health insurers as well.
It feels a bit like the dawn of a new era, which in many ways it is. For those who longed for the repeal of SGR (the sustainable growth rate formula for physician payment under Medicare), given the incredible kicking of that can down the proverbial road, may not have realized how significant its replacement would be.
But physicians and other clinicians, and medical and other informaticists, could really help to shape their future here, given that this is now a legislatively created regulatory mandate anyway.
And it will be fascinating to see what comes of this process. If (regulatory) winter is here, can (regulatory) spring be far behind?