Matthew T. Popovich, Ph.D.
ASA Monitor 07 2016, Vol.80, 56-57.
Matthew T. Popovich, Ph.D., is ASA Director of Quality and Regulatory Affairs.
According to the 2014 PQRS Experience Report, the average incentive for anesthesiologists who qualified for the incentive was $208, and the most CMS paid to an anesthesiologist was $6,734. Related to payment adjustments, anesthesiologists fared equal to or better than other specialties. As noted from the chart, just over 30 percent of anesthesiologists incurred a payment adjustment in 2016. Yet general surgery, geriatrics, hand surgery, neurosurgery, critical care, plastic surgery, vascular surgery and other specialties had higher payment adjustment rates. Specialties with lower payment adjustment rates among physicians included cardiology (26.7 percent), emergency medicine (28.3 percent) and radiology (25.7 percent).
Within the experience report, CMS indicated that EPs were more likely to meet reporting requirements and thresholds by using qualified registry, electronic health record (EHR), group practice reporting option or qualified clinical data registry. CMS also noted the increase in physicians, including anesthesiologists, who are using registry-based and EHR methods. Although claims may have been the mechanism of choice for reporting in 2014, claims nonetheless incurred the highest number of submission error rates. Of all incentives paid in 2014, just 14 percent of the total was awarded to EPs using the claims-based reporting mechanism.
So what does this mean for quality reporting under MACRA? It appears that CMS has known for some time the difficulties medical professionals have had in meeting PQRS standards that required an all-or-nothing approach to incentivizing and penalizing EPs. By disqualifying practices out-right who failed to satisfactorily report their individual measures, CMS could not ascertain the care that was provided to patients on the measures that were reported by the EP. Moreover, CMS also tracks the use of measures among EPs and removes those measures where they cannot adequately differentiate quality of care among providers. Identified as “topped out,” these measures are more likely to be de-emphasized under MACRA. Last, the trend toward non-process measures will continue as paying-for-value includes capturing patient outcomes, patient experience and satisfaction with their care, and the care coordination provided by multiple EPs for the patient.
CMS has indicated so much in a number of public forums and venues as well as in its release of the 2016 Measure Development Plan (MDP) and the MACRA Proposed Rule. In the MDP, CMS prioritized measures that follow the patient across the continuum of care, including the surgical care continuum, patient-reported outcome measures (including those related to functional status), measures that promote multiple levels of accountability (e.g., facility, EP, group) and measures that incorporate a “broader use of additional clinical and sociodemographic data.”
CMS will also scrutinize measures regarding their use and meaningfulness to patients, caregivers and clinicians. Similar to the MDP, CMS is looking at high-priority measures that include outcome, appropriate use, patient safety, efficiency, patient experience and care coordination. The measures that are most likely to be accepted into the programs for reporting purposes should include a data submission method beyond the claims-based method, address adverse events and address a performance gap. For scoring purposes under MIPS, measures that are approaching topped-out status may score fewer points than measures with an identified performance gap. Reporting outcome measures will allow the provider the ability to receive “bonus” points.
The transition from the known PQRS program to the proposed MACRA program will require that anesthesiologists and their practices understand where their strengths and challenges lie in identifying measures to report, the methods on how to report and how they can be fairly and accurately scored.