November 3, 2017
NCQA applauds CMS for strengthening the essential movement to paying Medicare clinicians for the value instead of the volume of care they provide. Important provisions in the rule include:
- A Medicare Advantage Alternative Payment Models (APMs) demonstration;
- Expressed interest from CMS in NCQA’s eMeasure Certification and vision of a system that obtains performance measurement data automatically from electronic health systems;
- Stronger requirements for multi-practice entities to get auto-credit for Patient-Centered Medical Homes and Patient-Centered Specialty Practices;
- Auto-credit for NCQA Patient-Centered Connected Care practices; and
- Virtual Groups, which allow small practices to join together to improve their ability to improve quality and have sufficient patients for quality measurement.
Medicare Advantage APMs: We especially support CMS plans to establish a demonstration program allowing Medicare Advantage plan APMs to count as MACRA APMs. Many Medicare Advantage plans already have robust APMs in place that are improving cost and quality for their enrollees. This demonstration is an important step toward harmonizing APMs from all payers, as the law requires starting in 2019. Such harmonization can greatly reduce burden on clinicians who now must meet different requirements for different insurers.
NCQA eMeasure Certification: We also appreciate CMS’ interest in NCQA’s eMeasure Certification and vision of a system that obtains performance measurement data automatically from electronic health records and other electronic data systems. This will greatly reduce clinicians’ reporting burden, improve the accuracy of results, and allow better measurement of outcomes that people most care about. NCQA just this week held a Digital Quality Summit to engage leading stakeholders in advancing this vision, and CMS can be a pivotal partner in expediting this important and timely work.
Patient-Centered Medical Homes & Patient-Centered Specialty Practices: We strongly support the final rule’s provision that 50% of practices within a Tax Identification Number (TIN) must have recognition for all practices to get auto-credit for the Clinical Practice Improvement Activities category in MACRA’s Merit-Based Incentive Payment System (MIPS). Previously, only 1 practice within a TIN needed recognition. The new rule brings the program closer to Congress’ intent when it stipulated auto-credit for PCMHs and PCSPs in the law.
NCQA’s Patient-Centered Connected Care: We greatly appreciate the final rule’s provision providing automatic credit for practices in NCQA’s Patient-Centered Connect Program. This program brings retail, employer, and other stand-alone clinicals into the medical neighborhood. The rule recognizes the effort and benefits of PCCC practices by providing auto-credit for both Clinical Practice Improvement Activities and Advancing Care Information categories of MIPS.
Virtual Groups: Finally, we are grateful that the rule lets small practices form Virtual Groups. Virtual groups can help small practices join together to have enough patients for robust measurement and prepare for APMs. Unfortunately, the rule prevents the smallest practices from joining virtual groups by defining “low-volume” practices as ineligible for MIPS. Low-volume practices – those with less than $90,000 in Medicare revenue or 200 Medicare patients –most need virtual groups so they can have reliable measurement and reap rewards for improvement. CMS could remedy this by amending its low-volume definition to say these practices are ineligible for MIPS “unless they join a virtual group.”