Centers for Medicare & Medicaid Services Quality Measurement and Program Alignment 1
Conflict of Interest Disclosure Deborah Krauss, MS, BSN, RN Maria Michaels, MBA, CCRP, PMP Maria Harr, MBA, RHIA Have no real or apparent conflicts of interest to report. 2
Learning Objectives This presentation will focus on alignment efforts across the Centers for Medicare & Medicaid Services (CMS) for Clinical Quality Measures (CQMs), highlighting the incorporation of meaningful use of EHRs in: CQM Selection Hospital Quality Reporting Eligible Professional (EP) Quality Reporting 3
CQM Selection 4
HHS, CMS, and National Quality Strategy BETTER HEALTH Care Coordination Population & Community Health Efficiency & Cost Reduction BETTER CARE Clinical Care Person / Caregiver Centered Safety LOWER COSTS 5
Quality: Multi-level Measurement & Improvement Community Population-based denominator Multiple ways to define denominator, e.g., county, HRR Applicable to all providers Practice setting Denominator based on practice setting, e.g., hospital, group practice Individual physician Denominator bound by patients cared for Applies to all physicians Greatest component of a physician s total performance Three levels of measurement critical to achieving three aims of National Quality Strategy Measure concepts should roll up to align quality improvement objectives at all levels Patient-centric, outcomesoriented measures preferred at all three levels The six domains can be measured at each of the three levels 6
CMS CQM Alignment Objectives Align with the National Quality Strategy and Six Measure Domains Implement CQMs that fill critical gaps within the six domains Align across programs whenever appropriate Leverage opportunities to align with private sector (e.g., NQF MAP), and focus on patient-centered CQMs (patient outcomes and patient experience). 7
CMS CQM Alignment Objectives (continued) Create parsimonious sets of CQMs core sets and measure concepts Maintain optional menu to apply to broad range of specialties and clinical practice of medicine in programs seeking broad, diverse participation Remove CQMs that are no longer appropriate (e.g., topped out) Maximize improvement in quality and minimize provider burden 8
CMS and HHS Measurement Policy Work Groups NQS Interagency Work Group CMS Grand Rounds HHS Measurement Policy Council HHS Measure Coordination Group CMS Grand Rounds CMS Quality Measures Task Force CMS Measures Forum Work Groups CMS Quality Improvement Council 9
CMS Quality and Performance Programs Hospital Quality Physician Quality Reporting PAC and OTHER Setting Quality Reporting Payment Model Reporting Population Quality Reporting Medicare and Medicaid EHR Incentive Program PPS-Exempt Cancer Hospitals Inpatient Psychiatric Facilities Inpatient Quality Reporting HAC Payment Reduction Program Readmission reduction program Outpatient Quality Reporting Ambulatory Surgical Centers Medicare and Medicaid EHR Incentive Program PQRS erx quality reporting Inpatient Rehabilitation Facility Nursing Home Compare Measures LTCH Quality Reporting Hospice Quality Reporting Home Health Quality Reporting Medicare Shared Savings Program Hospital Valuebased Purchasing Physician Feedback Physician Valuebased Modifier ESRD QIP Innovations Pilots Medicaid Adult Quality Reporting CHIPRA Quality Reporting Health Insurance Exchange Quality Reporting Medicare Part C Medicare Part D 10
CMS Measure Domains and Sub-domains Clinical Care Acute care Chronic care Prevention Clinical effectiveness Care Coordination Care transitions Admission and readmission Provider communication Population / Community Health Health behaviors Access to care Disparities in care (could also apply across domains) Measures should be patientcentered and outcome-oriented whenever possible Person- and Caregiver-centered Experience and Outcomes Experience of care Patient-reported outcomes Safety Patient safety Healthcareacquired infections and conditions Provider safety Efficiency and Cost Reduction Annual spend measures (e.g., per capita spend) Episode cost measures Form a core set of measures from measure concepts in each of the six domains that are common across providers and settings Greatest commonality of measure concepts across domains 11
CMS Measure Selection Criteria Core Criteria: Measure addresses an important condition/topic with a performance gap and has a strong scientific evidence base to demonstrate that the measure when implemented can lead to the desired outcomes and/or more appropriate costs (i.e., NQF s Importance criteria). Measure addresses one or more of the six National Quality Strategy Priorities (safety, care coordination, clinical care, population health, person- and family-centered care, making care more affordable). Measure promotes alignment with specific program attributes and across CMS and HHS programs Program measure set includes consideration for healthcare disparities Measure reporting is feasible. 12
CMS Measure Selection Criteria (concluded) Optional Criteria: Measure enables measurement using measure type not already measured well (e.g., outcome, cost, etc.). Measure enables measurement across the person-centered episode of care, demonstrated by assessment of the person s trajectory across providers and settings Program measure set promotes parsimony 13
CMS Measure Selection Process Prerulemaking Assessment of Impact of CQMs Program staff and Stakeholders suggest CQMs QMTF Prerulemaking CQM List, Dec 1st Prerulemaking MAP Feedback Feb 1st QMTF NPRM for each applicable program CQM Performance Review and Maintenance CMS implements CQMs in Final Rules QMTF Public comment on CQMs 14
Electronic Clinical Quality Measures (ecqms) Retooled Start with manual chartabstracted, paper-based specifications and translate as closely as possible to Health Quality Measures Format (HQMF) for EHR automated abstraction. CQM Specifications De Novo Developed from newly created measure concept into HQMF for EHR automated abstraction. CQM Specifications Paper Electronic Electronic 15
ecqms: Improvements in Development Standardization efforts in ecqm specifications Health Quality Measures Format (HQMF) Quality Reporting Document Architecture (QRDA) Q/A Review Goals in Creation of e-specifications National Library of Medicine: appropriate terminologies, value sets, testing, etc. Logic Review: frequent Stewards are involved throughout development processes Stakeholder input: early in process 16
CMS Examples of Program and Measurement Alignment 17
Vision for CMS Quality Reporting Programs Implement a unified set of electronic clinical quality measures (ecqms) and e-reporting requirements to synchronize and integrate CMS quality programs and reduce provider reporting burden. 18
Goals for CMS Quality Reporting Programs Improve quality of care using robust CQMs, timely feedback to hospitals and physicians, and meaningful use of EHRs. Minimize burden by: Synchronizing performance and submission periods. Allowing participating providers to make one submission of ecqm data for multiple programs. Using the same CQMs and electronic specifications across programs. Maximize efficiency by using ecqm data submitted by providers for multiple quality programs. 19
Alignment Elements* Program Design Quality Improvement Goals: HHS, CMS, and National Quality Strategies CQM Harmonization Populations Measured / Sample Size Program Performance / Reporting Periods Program Submission Periods Payment Adjustment Timelines Appeals Rulemaking Vehicles and Timelines Outreach, Communication, and Public Engagement Program Ownership Privacy and Security Data and Systems Type and Format Source Measure e-specifications Level (aggregate, patient, or hybrid) Submission Pathway Storage Validation * Many of the elements are governed by statutory requirements 20
Hospital Quality Programs 21
Transition to EHR Reporting for Hospitals 2011 2017 EHR Incentive Program (Stage 1, 2, 3) IQR: Transition to ecqms Other Hospital Quality Reporting Programs (HVBP, OQR, etc.): Transition to ecqms Transition to EHR Reporting ecqm Electronic Clinical Quality Measure IQR Inpatient Quality Reporting HVBP Hospital Value-Based Purchasing OQR Outpatient Quality Reporting 22
Hospital Program Alignment: Key Considerations Over 99% of hospitals participate in the IQR/HVBP programs. Statutory requirement: CQMs must be included in IQR and displayed on Hospital Compare for one year before an HVBP performance period starts. CMS obtains feedback from hospitals and associations to build on current IQR/HVBP approach when aligning with EHR Incentive Program. CMS will continue to electronically specify CQMs, introduce them through the EHR Incentive Program, and then transition sets of measures over time to electronic reporting in IQR, HVBP, and other hospital reporting programs. 23
Hospital Program Alignment Using ecqms CEHRT 1 Hospitals ecqms QRDA 2 I 1 Certified EHR Technology 2 Quality Reporting Data Architecture 1. Meaningful Use 2. IQR 3. HVBP 4. Other CMS Quality Reporting Programs 24
Hospital Program Alignment: Timeline By 2013: Complete alignment of HVBP and IQR CQMs reported on Hospital Compare. Implementation of the Medicare EHR Incentive Program Electronic Reporting Pilot for Eligible Hospitals and Critical Access Hospitals. (Note: This electronic reporting pilot will be the basis for electronic reporting in other reporting programs.) By 2014: IQR will introduce EHR-based reporting. Additional details will be included in the FY2014 Inpatient Prospective Payment Schedule proposed rule that is targeted for publication in Spring 2013. Beyond 2014: CQMs will be transitioned to EHR-based reporting in the EHR Incentive Program and then to IQR and other hospital reporting programs. 25
Eligible Professional (EP)* Quality Programs * NOTE: EP is a term used in the EHR Incentive Program. Other programs may have other terms for participants (e.g., ACOs). 26
Transition to EHR Reporting for EPs 2011 2017 EHR Incentive Program (Stage 1, 2, 3) PQRS: Transition to ecqms Other EP Quality Reporting Programs (VBM, ACOs, etc.): Transition to ecqms Transition to EHR Reporting ecqm Electronic Clinical Quality Measure PQRS Physician Quality Reporting System EP Eligible Professionals 27
EP Program Alignment: Key Considerations Quality Measures Reported PQRS and EHR Programs are aligned on the same set of ecqms (64 total) and the same electronic specifications beginning in 2014. Data Origination If submitted electronically, the data submitted for both programs must originate from CEHRT. Submission Methods Participating EPs have the option to submit patient-level data (via QRDA I) or aggregate data (via QRDA III) using the same reporting mechanism for electronic reporting. 28
EP Program Alignment Using ecqms CEHRT 1 Individual EPs/Groups ecqms QRDA 2 I or QRDA III 1 Certified EHR Technology 2 Quality Reporting Data Architecture 1. Meaningful Use 2. PQRS (including PROs) 3. ACOs 4. Value-Based Modifier 5. Other CMS Quality Reporting Programs 29
EP Program Alignment: Timeline By 2013: Individual EPs Implementation of the PQRS-EHR Incentive Program Pilot (Note: Can fulfill the CQM component of meaningful use as well as PQRS if reported using QRDA I). Group Practices PQRS Group Practice Reporting Option (GPRO) web interface CQMs aligned with those in the ACO GPRO measure set and the VBM GPRO measure set. PQRS aligned with the Physician Value-Based Modifier (VBM), whereby the quality component of the 2015 VBM for group practices with 100 or more eligible professionals that elect quality tiering will be based on the groups performance on PQRS measures. 30
By 2014: EP Program Alignment: Timeline (concluded) Individual EPs CMS previously finalized full alignment of PQRS EHR reporting options, including CQMs, reporting criteria, and reporting mechanism in the CY 2013 Physician Fee Schedule (PFS) and the Stage 2 rules. Group Practices CMS also previously finalized in the CY 2013 PFS and Stage 2 rules that group practices participating in the PQRS GPRO or ACOs using CEHRT and reporting via the GPRO web interface fulfill the requirement of the CQM component of meaningful use. 31
Electronic Reporting Pilots (2012 and 2013) Pilot participation in 2012: EPs: 9700+ (as of last week of 2/2013) Hospitals: 4 Pilot participation in 2013: EPs MU CQMs + PQRS -> QRDA I using PQRS specifications Hospitals Both 2011 and 2014 e-specifications will be accepted 32
Summary Standards are key to building interoperability between EHRs Focus of alignment efforts is with EHR-based reporting of ecqms Alignment with national, HHS, and CMS Quality Strategies Alignment across CMS programs, including: CQMs selected CQM specifications Reporting mechanisms Reporting schemas Reporting/performance and submission periods 33
Questions? 34