Accountable care organizations need more time to adjust to new quality reporting requirements for the Medicare Shared Savings Program set to take effect in 2022, group purchasing and consulting organization Premier told CMS in a letter last week.
The organization, which serves about 4,100 hospitals and health systems, said the COVID-19 pandemic has made it difficult for providers to devote the time and resources necessary to make the required changes.
"We appreciate the one-year delay that CMS finalized for 2021, as this provided ACOs with an additional performance year to continue with the Web interface while still testing new options. However, CMS should delay requirements or provide an exemption in 2022 for ACOs that may need additional time to transition to these new requirements," the letter said.
But Premier stressed that it supports the policy changes, including fewer quality measures and allowing ACOs to report those measures outside the CMS Web Interface.
"We understand CMS' intent is to assess the quality of care across all patients and all payers, similar to the approach CMS uses in other quality reporting programs. However, the MSSP program is fundamentally different than setting- and provider-specific quality reporting programs. ACOs are a network of aligned providers rather than a specific provider type," the letter said.
The organization asked CMS to make several changes to ease ACOs' transition to the new reporting requirements, including limiting ACO reporting to aligned populations, starting with lower data completeness and clarifying and establishing quality benchmarks in advance. Premier also wants CMS to seek additional input on MSSP's quality measure set and keep the pay-for-reporting option for new entities or newly introduced or modified measures.
"We believe that the stated strategic goal of aligning the MSSP quality standard with the MIPS quality performance category is misguided," the letter said. "Alternative payment models, or APMs, should not have to align with MIPS. Rather MIPS reporting requirements should be structured to encourage clinicians to adopt APMs."
Premier noted that while some ACOs have a single electronic health record system, most have multiple EHRs. That makes it tougher for them to change how they report quality data.
"This reflects varying approaches to including participant practices in the ACO, which ranges from employment to alignment," the letter said.
CMS last December finalized its plans to align MSSP quality measures with those in the Quality Payment Program, giving ACOs more time than originally proposed.
ACOs have two more years before quality performance standards increase from the 30th percentile of the benchmark to the 40th percentile. CMS initially planned for the changes to take effect at the start of 2021, but ACOs pushed back, arguing it was too much change as they continue to deal with COVID-19.
Additionally, ACOs have an extra year before they need to sunset use of the CMS Web Interface, which ACOs use to report quality measures. ACOs will instead report quality measures through vendor platforms currently approved for MIPS. ACOs pushed back against the change, pointing to strains from COVID-19 that would mitigate efforts to train staff to use a new platform.
CMS also moved forward with modifying quality measurement in the ACO program. Starting in the 2021 performance year, ACOs will be required to report either 10 measures to the CMS web interface or three clinical quality measures under MIPS, which ACOs can report electronically. Then in the 2022 performance year, all ACOs must report the three clinical quality measures under MIPS. By 2022, CMS will use just six quality measures to determine quality performance in the program.
