Value-Based Care News

Quality Measure Change May Impact Medicare ACO Performance

Changes to a tobacco screening and smoking cessation measure during the 2018 performance period could negatively affect Medicare ACO performance, NAACOS warned.

Medicare accountable care organizations (ACOs)

Source: Thinkstock

By Jacqueline LaPointe

- Medicare accountable care organizations (ACOs) performance may suffer after CMS unexpectedly modified a quality measure during the 2018 Medicare Shared Savings Program (MSSP) performance period, the National Association of ACOs (NAACOS) recently announced.

The quality measure at the center of the controversy is ACO-17, Preventive Care and Screening, Tobacco Use – Screening and Cessation Intervention.

ACOs completing their 2018 MSSP quality reporting were surprised to discover that CMS made significant specification changes to ACO-17 compared to the previous performance year, NAACOS explained in a letter to John Pilotte, director of the performance-based payment policy group at CMS.

Specifically, CMS changed the denominator of the quality measure. Previously, the measure had one denominator: patients with an applicable office visit within the specified age requirements.

In 2018, however, CMS divided the measure’s denominator into three separate populations, with the second population being used for scoring. The second population is patients who were screened for tobacco use and identified as a tobacco user.

READ MORE: Understanding the Fundamentals of Accountable Care Organizations

The change in denominator resulted in some ACOs seeing a 30 percent or greater drop in their MSSP performance scores on the measure from 2017 t0 2018, NAACOs reported.

“ACOs that do not meet quality standards are not eligible to share in any potential savings they may earn,” the association wrote. “Additionally, ACO shared savings rates may be affected by their quality performance scores. Therefore, addressing the issues related to ACO-17 as detailed below will be critical to ACOs; not doing so could result in certain ACOs limiting or even eliminating their shared savings opportunities.”

The quality measure change could also impact patient satisfaction, ACOs said. Primary care providers would have to conduct a subsequent tobacco screening on patients who recently received a tobacco screening and smoking cessation intervention at their last visit regardless of how much time passed or the reason for the subsequent visit.

“To repeat the conversation again would be duplicative and potentially lead to lower patient satisfaction and greater frustration,” NAACOS stated.

Not only could the quality measure change impact Medicare ACO performance in terms of shared savings and patient satisfaction, but the organizations are also concerned that CMS did not communicate the quality reporting change.

READ MORE: For Ongoing ACO Shared Savings, Look Outside Inpatient, Primary Care

“The specification changes for this measure from 2017 to 2018 are significant, however these changes were not communicated to ACOs until just recently when quality reporting for 2018 was already underway,” NAACOS emphasized.

Transparency and communication have been major challenges for Medicare ACOs.

NAACOS recently called out the agency’s innovation arm for a lack of transparency in a letter urging the Innovation Center to develop a more methodical and public process for releasing and updating alternative payment models (APMs) like the MSSP.

“To accelerate participation in APMs and the move to performance-based risk, we request that the Innovation Center continue to take steps to improve transparency and stability,” they stated in the March 26 letter to CMS Administrator Seema Verma and Deputy Administrator of CMMI Adam Boehler.

“As you know, responsibly moving to higher levels of financial risk requires a steady and predictable payment environment. This allows organizations to plan their budgets and care coordination activities and to predict how they will fare under any given model. Creating clarity and stability for model design will encourage provider organizations to move to higher levels of risk and reward more quickly.”

READ MORE: How Accountable Care Organizations Can Prepare for Downside Risk

The American Medical Group Association (AMGA), Association of American Medical Colleges (AAMC), Health Care Transformation Task Force, Medical Group Management Association (MGMA), and others also signed the letter.

In the case of ACO-17, NAACOS advised CMS to make the measure pay-for-reporting for two performance years in light of the significant changes.

According to federal law, CMS must introduce measures to the MSSP by setting the level of “complete and accurate reporting,” otherwise known as pay-for-reporting, for the first two performance periods for which reporting of the measure is required.

For example, CMS followed the process for ACO-11, Use of Certified EHR Technology. The measure went from assessing the use of certified EHR technology among primary care providers to assessing the use of the technology across all eligible clinicians in the ACO.

Following the change, CMS made the measure pay-for-reporting for two years.

“We feel strongly that CMS must similarly make ACO-17 (Prev-10, NQF 0028), Preventive Care and Screening, Tobacco Use- Screening and Cessation Intervention, pay-for-reporting only for two performance years beginning with the 2018 Performance Year,” NAACOS wrote.

“If CMS does not address this issue, ACOs will be negatively affected and could miss out on shared savings opportunities,” the letter concluded.