Author: Matthew T. Popovich, Ph.D.
ASA Monitor 03 2017, Vol.81, 40-41.
Matthew T. Popovich, Ph.D., is ASA Director of Quality and Regulatory Affairs.
Each winter and spring, anesthesiology and pain medicine practices choose their quality measures to report to the Centers for Medicare & Medicaid Services (CMS) and a reporting mechanism to use. For anesthesiology, measures reportable under the Merit-based Incentive Payment System (MIPS) are identified via the Anesthesiology Measure Set or a combination of that measure set and non-MIPS Qualified Clinical Data Registry (QCDR) measures. But for pain medicine physicians, the choice of measures is more ambiguous and not necessarily one that is easy to define.
Quality measures are often structured as a basic mathematical fraction. The denominator represents the patient population and is typically created by identifying patient demographics, such as age or diagnosis, and CPT® Codes billed by the eligible clinician. For anesthesiologists who bill CPT® Codes starting with “0,” the choice of measures based upon patient population is rather straight-forward. A diverse set of measures is available for pain medicine physicians who bill evaluation and management codes as well as blocks, injections and other clinical interventions. Once the denominator is met, the numerator of a measure must be reported to complete the measure. The numerator describes a patient outcome or the clinical process or action performed.
Under the Physician Quality Reporting System (PQRS), eligible professionals, such as anesthesiologists and pain medicine physicians, were required to report nine measures across three National Quality Strategy domains for a majority of their patients. If practices had fewer than nine measures to report, CMS required an individual to report on all measures that applied to their patients. For anesthesiologists, this resulted in some practices reporting just one or two measures while other practices reported on upward of seven or eight measures. For pain medicine physicians, nine measures could often be met, but the clinical significance of reporting these nine measures often failed to fully capture the care such physicians provide to patients.
Although the Quality Component of MIPS replaced PQRS in 2017 and lowered the number of measures required to report to just six, the measures available to pain medicine physicians changed little in the transition. Measures applicable to pain medicine physicians who bill office visits often reflect more primacy care activities, such as pneumococcal vaccination status of older adults (MIPS #111), body mass index screening (MIPS #128) and screening for clinical depression (MIPS #134). Those physicians may also report measures related to performing a risk assessment for falls (MIPS #154), screening for elder maltreatment (MIPS #181) and screening and cessation intervention for tobacco use (MIPS #226). MIPS #131, Pain Assessment and Follow-Up, and MIPS #342, Pain Brought Under Control within 48 Hours for Palliative Care patients, also represent two quality measures pain medicine physicians may report.
Recent emphasis on the opioid epidemic has pushed the measurement community to develop measures aimed at effective and safe use of opioids. In 2016 and again in 2017, pain medicine physicians have the opportunity to report three such measures: Opioid Therapy Follow-Up Evaluation (MIPS #408), Documentation of Signed Opioid Treatment Agreement (MIPS #412) and Evaluation or Interview for Risk of Opioid Misuse (MIPS #414).
Pain medicine practices have, just like other specialties, begun to report their measures via qualified registry, QCDR or Certified Electronic Health Record Technology (CEHRT) in greater numbers. In 2017, some of the measures available to pain medicine physicians continue to be available to report via claims. But commentary from CMS on MIPS regulation indicates that fewer of these claims-based measures may be available in future years. At the same time, the agency has indicated a preference for reporting via qualified registry or QCDR (because practices can track their progress throughout the year and registry participants have fewer errors in reporting) and CEHRT (CMS offers bonus points for measures reported via CEHRT).
As a qualified registry and QCDR, the Anesthesia Quality Institute’s (AQI’s) National Anesthesia Clinical Outcomes Registry (NACOR) allows practices to report on more than two dozen MIPS quality measures and other non-MIPS QCDR measures. Quality measures specific to pain medicine physician needs are part of the AQI NACOR offering for 2017. Each year, physician leaders and staff work together to ensure that ASA members and other AQI NACOR participants have the opportunity to report on measures that reflect their previous reporting and local practice initiatives. This year, both anesthesiologists and pain medicine physicians will find more than a sufficient number of measures available for them to report to CMS and fulfill their MIPS Quality Component requirements.
Within the medical community, physicians and other clinicians have bemoaned the lack of meaningfulness among many of the available quality measures. Screening for depression or vaccination status, many claim, does not necessarily reflect the high-quality care that pain patients seek and pain medicine physicians strive for each day. Indeed, many of those same clinicians see quality measurement as an unnecessary burden of checking the check box instead of capturing meaningful clinical actions or patient outcomes. However burdensome the requirements are among physicians, the need to participate and do well under the current payment system often is the key driver behind quality reporting in health care.
In this first year of MIPS, as anesthesiologists and pain medicine physicians choose their measures to report for the MIPS Quality Component, physicians and their practices are encouraged to choose measures that most reflect their practice, measures where their performance is strong and measures that can be captured and reported for most of the year. ASA provides these services through the Anesthesia Quality Institute and has developed a process for greater engagement of members on quality measure development.