Beginning with the 2021 Reporting Year, ACOs will have a new way to report data to CMS: The APM Performance Pathway, also known as the “APP”.
While the 2021 CMS Final Rule frames 2021 as a transition year, in which Web Interface submission is still available alongside reporting via APP, beginning in 2022, the Web Interface option will no longer be available.
Developed as a companion to MIPS Value Pathways (MVPs), the APP is working to reduce the regulatory reporting burden for ACO’s. APP reporting will do this by reducing the number of entity-reportable Quality Measures from ten (10) Web Interface Measures to just three (3) eCQM/CQM measures that need to be reported by the ACO. CMS will also calculate 2 Administrative Claims measures, and ACOs must report CAHPS1 for MIPS survey2.
On its face, this appears to be a huge burden reduction! Fewer measures means less data to send, right?
Well, the answer is yes… and no.
Yes, ACO’s will now only need to report three (3) CQM/eCQM measures:
- Quality ID 001 - Diabetes Hemoglobin A1C Poor Control
- Quality ID 134 - Screening for Depression and Follow up Plan
- Quality ID 236 - Controlling High Blood Pressure
So technically it's fewer measures than the 10 Web Interface measures required in previous years. And yes, these measures represent the variety of practice types that make up APM Entities. They are widely used measures in the primary care space occupied by many APM participants. So in theory there should be less effort.
However, these new measures don’t necessarily mean less data.
Here’s where things get a little more complicated: In order to meet data completeness for the three (3) CQM/eCQM measures, ACOs need to look at their entire patient population, (not just Medicare Part B) and increase their Denominator to reflect that.
Here are the big Quality Category data hot points:
- Measure denominator must include all payers. This is a huge change from previous years where the beneficiary sample was 248 medicare beneficiaries.
- Measure data completeness must be met. These rules follow traditional MIPS guidelines, and include all denominator eligible patients. Measure data must be combined/aggregated across all TINs included in the ACO, even those on paper.
So now there are fewer measures to report, but the population that must be measured has grown exponentially.
This is where Patient360 can help.
As a CMS Qualified Registry, Patient360 brings 14 years of Quality Program Reporting experience to your ACO, allowing for confidence in the scoring engine that will make this new reporting program successful for your organization.
The Patient360 scoring engine accurately monitors and tracks performance metrics across the ACO, participating TINs, and the individual NPIs. These tools identify gaps and possible shortcomings before the time comes to submit to CMS.
That being said, the biggest challenge facing ACOs on their APP adventure comes with combining (or aggregating) all of the requisite patient data from disparate EMR/EHR, PM, billing and even residual paper systems. (Yes, we know there are still a few of you out there on paper!)
As a CMS approved registry, with years of experience in aggregating data in support of CMS submission, Patient360 is an invaluable partner in the new APP submission process. Without an experienced registry like Patient360, ACOs risk incomplete and/or inaccurate data capture across all ACO participants. Complete and accurate data capture is necessary to optimally (and in a compliant fashion) report the overall ACO-level performance.
Most ACOs inevitably must access numerous EMR/EHR/PM vendors utilized by their providers. An approved Medicare Registry like Patient360 has a proven track record fulfilling data aggregation requirements that are now at the core of APP reporting.
While Web Interface is still around in 2021, and your organization has a choice to delay for one more year, industry leaders recommend ACOs begin looking at the changes now. Experience will be your friend if you start with APP and eCQM/CQM reporting based on the new rules… even if it is to do both methods during the 2021 transition year. In 2022 when Web Interface sunsets and is gone forever, the APP and eCQM/CQM measures will be the only option for reporting quality data. If you wait, you risk being behind the curve and at a disadvantage in 2022.
Here is what you can do today in preparation for 2021 & 2022 reporting:
- Understand the eCQM/CQM measure specifications
- Know the impact of the all-payer requirement
- Review Data completeness requirements
- Adjust Provider Workflows and Documentation
- Plan data flow and aggregation