CMS QUALITY PROGRAMSAlabama Hospital AssociationOctober 2019
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CMS Strategic Priorities for 2019
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Quality Measurement
• What Makes a Good Quality Measure? (reliability, feasibility, validity, no unintended consequence, meaningful, impactful)
• Process of Measure Selection and Creation
o Where do Measure Ideas get generated?
o Conceptualization of a Measure
o Development and Testing
o Endorsement
o Use in a Public Program
o Assessment of Impact
o Public Feedback
o Harmonization
• For detailed information view Measure Blueprint
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Meaningful Measures Framework
eCQM Strategy ProjectApproach to Learn Stakeholder Experiences
Transparency
• Transparency important so that patients have access to information to make best healthcare choices. Transparency has also engaged organizations in more quality improvement.
• Star ratings and transparency for patientso My Health e-data for patients o Nursing Home Compareo Hospital Compareo Physician Compare
• Price Transparency• Quality Data Strategy
o More rapid feedback to clinicianso API development for sharing quality datao Sharing data more broadly for research
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Alignment
• One source of burden and confusion is that quality measures are not always aligned across all payers.
• CMS is engaged in multiple initiatives to promote alignment: o CQMC – Core Quality Measures Collaborative – between AHIP (Americas Health Insurance Plans),
NQF and CMS to determine core ambulatory measures which can be agreed upon for ALL payers
o Alignment efforts across CMS – Medicare FFS (traditional measures), Medicare Advantage, Medicaid, CMMI
o Alignment efforts with VA and DOD per Presidential Executive Order
o Alignment and efforts to review the CMS Measure Inventory (CMIT) to eliminate redundancies and measures with changed clinical evidence or measures that are topped out
o Alignment efforts with QCDR (qualified clinical registries) to promote alignment and sharing of measures
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Do We Need SDS Adjustment and if so, HOW?
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• Dual Eligible Status
• Specific Risk Adjustment Factors
o REL
o Safety Net/DSH payments
o Transportation
o Food Availability
o Literacy/Education
o Community Characteristics (“stressed cities”)
QMVIG Value Based Programs
• Hospital Inpatient Quality Reporting Program
• Hospital Value Based Purchasing Program and Stars Program
• Hospital Outpatient Quality Reporting Program
• Ambulatory Surgical Centers Quality Reporting Program
• Inpatient Psychiatric Facility Quality Reporting Program
• ESRD Quality Incentive Program
• Hospital Acquired Condition Reduction Program
• Hospital Readmissions Reduction Program
• Merit Based Incentive Payment System (MIPS)
• Prospective Payment System for Exempt Cancer Hospital Quality Program
• Skilled Nursing Facility Value Based Program
• Home Health Quality Reporting Program
• Hospice Quality Reporting Program
• Inpatient Rehabilitation Facility Quality program
• Long Term Care Hospital Quality Reporting Program
• Promoting Interoperability – Hospital Program and Eligible Provider Program
• Marketplace – QRS Measure Set and Stars Program
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Quality Measurement and Value Based Incentives Group
HOSPITAL STARS
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Hospital Stars Overview
• Overall Hospital Quality Star Ratings (“Star Rating”) publicly launched on Hospital Compare in July 2016
• Purpose: To summarize quality measure information on Hospital Compare in a way that is useful and easy to interpret for patients and consumers (single star rating)
o Complement other quality information tools, individual measures and Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) star rating
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Timeline
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Opportunities for Improvement
• CMS is considering changes to the Star Ratings methodology
o Increase simplicity of the methodology, predictability of star ratings over time, and comparability of hospitals
• Through ongoing reevaluation activities, including stakeholder engagement:
o Technical Expert Panel, Provider Leadership Work Group, and Patient & Advocate Work Group meetings
o Listening sessions (August 2018)
o Public comment (most recently in Spring 2019)
o NQF Panel (August 2019)
o CMS Listening Session (Fall 2019)
o New Technical Expert Panel and Work Groups (Fall 2019)
o Rulemaking (2020)
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Patient & Consumer Engagement
• The patient voice has been incorporated in Star Ratings since project inception:
o Five meetings with the Patient & Patient Advocate Work Group
o Four public input periods
o Listening Sessions targeting patients and consumers
“From a consumer perspective, consumers want to know what is the best hospital. And what we are using for that is how they are doing on their star ratings. I think that is the clearest representation for consumers.”
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Patient & Consumer Feedback
• Concept and display of Star Ratingso Patients agreed a single rating would increase accessibility of quality information on Hospital Compareo Additional information on measure groups, data, and methodology should be included on separate pages for those
interested
• Measure groupings and weightso Outcome and patient experience measure groups more important to consumers
• Feasibility of domain star ratingso Available measures don’t allow for meaningful domain star ratings
• Concept of peer groupingo Could confuse consumers, not useful to consumers, but could be provided on a separate page
• Approaches to incorporate improvemento Could confuse consumers, not useful to consumers, and Star Ratings should reflect most current data
• Usability of user-customized star ratingso Could be useful or complicated for consumers
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Potential Methodology Updates
• Based on stakeholder input CMS is considering the following potential methodology updates:
o Selection of Measures: Impact of Meaningful Measures Initiative (Step 2)o Scoring Approaches: Analysis of Latent Variable Modeling and Potential
Alternatives (Explicit Approach) (Step 3)o Patient Risk: Social Risk Factor Adjustment of Readmission Measure Group
(Step 3)o Peer Grouping (between Steps 5 and 6)
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Potential Methodology Updates
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Changes to
Available
Measures
(Meaningful
Measures)
Impact of
Meaningful
Measures
Initiative
Alternatives to
Latent Variable
Modeling
Social Risk
Factor
Adjustment of
Readmission
Measure Group
TBD
Measure
Reporting
Threshold
Peer
Grouping
Meaningful Measure Initiative
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Star Ratings Measure Group
# of Measures in Each Group
(Feb19)
# of Planned Measure
Removals in Each Group
Measure Removals
# of Planned Measure
Additions in Each Group
Measure Additions
Mortality 7 0 0
Safety of Care 8 0 0
Readmission 9 1 READ-30-STK 2 OP-35; OP-36
Patient Experience
10 0 0
Effectiveness of Care
11 4IMM-2; OP-4; OP-30; VTE-6
0
Timeliness of Care
7 5ED-1b; ED-2b; OP-5;
OP-20; OP-210
Efficient Use of Medical Imaging
5 2 OP-11; OP-14 0
Next Steps
• Listening Session at NQF August
• Listening Session at CMS September
• New TEP to be convened in November
• Proposals will enter formal rule writing cycle
• Refresh of Stars using current methodology January 2020
• Modernized Stars using revised methodology target January 2021
• Another separate next step is research discussions (CMMI/CCSQ) regarding a unified hospital value based pilot –still in beginning stages
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QUALITY PAYMENT PROGRAM
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Provider Engagement: Quality Payment Program
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The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) requires CMS by law to implement an incentive program, referred to as the Quality Payment Program:
• Comprised of four performance categories
• So what? The points from each performance category are added together to give you a MIPS Final Score
• The MIPS Final Score is compared to the MIPS performance threshold to determine if you receive a positive, negative, or neutral payment adjustment
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100 Possible Final Score
Points
=
MIPS Performance Categories
Quality Cost Improvement Activities
PromotingInteroperability
+ + +
Merit-based Incentive Payment System (MIPS)
Quick Overview
MIPS Year 4 (2020) Proposed Changes
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Performance Category Weights
Performance Category
Performance Category Weight
Quality
45%
Cost
15%
Improvement Activities
15%
Promoting Interoperability
25%
Performance Category
Performance Category Weight
Quality
40%
Cost
20%
Improvement Activities
15%
Promoting Interoperability
25%
Year 3 (2019) Final Year 4 (2020) Proposed
MIPS Value Pathways
CMS is proposing MIPS Value Pathways (MVPs) to create a new participation framework beginning with the 2021 performance year. This new framework would:
• Unite and connect measures and activities across the Quality, Cost, PromotingInteroperability, and ImprovementActivitiesperformance categories of MIPS
• Incorporate a set of administrative claims-based quality measures that focus on population health/public health priorities
• Streamline MIPS reporting by limiting the number of required specialty or condition specific measures
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Request for Information
MIPS Value PathwaysGoal is alignment with specialty societies where feasible
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Future State ofMIPS(In Next 3-5Years)
Current Structure ofMIPS(In 2020)
New MIPS Value PathwaysFramework(In Next 1-2Years)
Building Pathways FrameworkMIPS Value Pathways
Clinicians report on fewer measures and activities baseon specialty and/or outcome within a MIPS ValuePathway
Moving toValue
Fully ImplementedPathwaysContinue to increase CMS provided data and feedback to
reduce reporting burden on clinicians
• Many Choices
• Not Meaningfully Aligned
• Higher Reporting Burden
• Cohesive
• Lower Reporting Burden
• Focused Participation around Pathways that are Meaningful to Clinician’s Practice/Specialty or Public Health Priority
• Simplified
• Increased Voice of thePatient
• Increased CMS Provided Data
• Facilitates Movement to Alternative Payment Models (APMs)
2-4Activities
ImprovementActivities
Quality
6+Measures
PromotingInteroperability
6+Measures
Cost
1 or MoreMeasures
Cost
Quality and IA aligned
Foundation
Promoting Interoperability
Population Health Measures
Foundation
Promoting Interoperability
Population Health Measures
Enhanced Performance Feedback
Patient-Reported Outcomes
Value
Quality ImprovementActivities
Cost
We Need Your Feedback on:
Population Health Measures: a set of administrative claims-based quality measures that focus on public health priorities and/or cross-cutting population health issues;
CMS provides the data through administrative claims measures, for example, the All-Cause Hospital Readmissionmeasure.
Goal is for clinicians to report less burdensome data as MIPS evolves and for CMS to provide more datathrough
administrative claims and enhanced performance feedback that is meaningful to clinicians and patients.Clinician/Group Reported Data CMS Provided Data
Pathways:
What should be the structure and focus of the Pathways? What criteria should we use to select measures and activities?
Participation:
What policies are needed for small practices and multi-specialty practices?Should there be a choice of measures and activities withinPathways?
Public Reporting:
How should information be reported to patients?
Should we move toward reporting at the individual clinician level?
MIPS Value Pathways: Surgical Example
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MIPS moving towards value; focusing participation on specific meaningful measures/activities or public health priorities;facilitating movement to Advanced APMtrack
2-4Activities
ImprovementActivities
Quality
6+
Measures
PromotingInteroperability
6+
Measures
Cost
1 or MoreMeasures
Population Health Measures: a set of administrative claims-based quality measures that focus on public health priorities and/or cross-cutting population health issues; CMS provides the data through administrative claims measures, for example, the All-Cause Hospital Readmissionmeasure.
Completion of an Accredited Safety or Quality Improvement Program(IA_PSPA_28)
Patient-Centered Surgical Risk Assessment and Communication (Quality ID:358) OR
Implementing the Use of Specialist Reports Back to Referring Clinicianor Group to Close Referral Loop (IA_CC_1)
Revascularization for Lower Extremity Chronic Critical Limb Ischemia (COST_CCLI_1)
Knee Arthroplasty (COST_KA_1)
Surgical Site Infection (SSI) (Quality ID:357)
Use of Patient SafetyTools (IA_PSPA_8) Medicare Spending Per Beneficiary (MSPB_1)Unplanned Reoperation within the 30-Day Postoperative Period (Quality ID: 355)
QUALITY MEASURES
MIPS Value Pathways for Surgeons
COST MEASURES
*Measures and activities selected for illustrative purposes and are subject to change.
IMPROVEMENT ACTIVITIES
Surgeon reports on same foundation of measures with patient-reported outcomes also included
Performance category measures in Surgical Pathway are more meaningful to thepractice
CMS provides even more data (e.g. comparative analytics) using claims data and surgeon’s reporting burden evenfurther reduced
Surgeon chooses from same set ofmeasures as all other clinicians, regardless of specialty or practicearea
Four performance categories feel likefour different programs
Reporting burden higher and population health not addressed
Surgeon reports same “foundation” of PI and population health measures as all other cliniciansbut now has a MIPS Value Pathway with surgical measures and activities aligned with specialty
Surgeon reports on fewer measures overall in apathway that is meaningful to theirpractice
CMS provides more data; reporting burden onsurgeon reduced
Clinician/Group CMS Clinician/Group CMSClinician/Group CMS
ImprovementActivities
CostQuality
Foundation
Promoting Interoperability
Population Health Measures
Foundation
Promoting Interoperability
Population Health MeasuresEnhanced Performance Feedback
Patient-Reported Outcomes
Future State of MIPS(In Next 3-5 Years)
Current Structure of MIPS(In 2020)
New MIPS Value PathwaysFramework(In Next 1-2 Years)
Cost
Quality and IA aligned
Accountable Care Organizations
• What is the patient understanding of ACO’s?
• What is the future of value based purchasing?
• What is the future of specialty quality programs?
LOOKING AHEAD
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Preparing for the Future of Value Based Care
• How Can QI Teams Prepare for Next Stages of Transformation to Value?
• How Can We Engage Clinicians in Quality Improvement – specifically using EHR?
• Comment:o Commitment to Continuous Learning and Continuous Quality Improvement – including trained in skills of QI (Lean, PDCA,
High Reliability)
o Data Analytic Systems and Support – needs to be at an individual physician level, easy to understand, tied to performance
o Governance systems that support quality and CQIo Understanding of costs (very hard to do)
o Engagement of, and listening to, customers (do you post individual pt. experience scores; are you tracking patient reported outcomes)
o Transparency to patients – use of patient portal, Open Notes, Test results available immediately
o Physician engagement in EMR – physician builders, participation with IT teams, assessment of individual’s use for efficiency (reduce burden)
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Interoperability
• Interoperability essential
o Create seamless care and knowledge across the continuum of care – all sites, any time
o Ensure patients have access to information to make appropriate care choices
o Ensure providers have access to information for best care and performance
o Timely and actionable feedback
o Unleash “big data” analytics and innovation
• CMS and ONC interoperability
o To promote sharing of information
o Prevent information blocking
o Accelerate path of electronic data sources for performance feedback (quality measures, cost)
o Transparency – pricing, quality, experience
o Use of certified technology
o FHIR and API standardization
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Key Directions for CMS
• Transparency – Price Transparency, Quality Transparency, Performance Transparency
• Engaging Consumers – Compare Websites
• Engaging Governance
• Continued Pursuit of Value Based Models
• Key Quality Areas:o Maternal Mortality
o Pain Management/Substance Abuse/Opioids
o Skilled Nursing Facility Safety
o Healthcare Safety – High Reliability, Safety Events, Electronic Safety Reporting of Events, Diagnostic Error
o Post Acute Care – alignment, frailty assessment
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Technical Assistance
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