Reporting on Quality Measures in Specialty Practices

Urologists, oncologists, or other specialty physicians should not be judged solely by the same quality measures used by internists when it comes to reporting quality data to CMS, most would agree.

With the advent of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), physicians are incentivized in a different way to provide high-value care to their patients. Reporting on the quality measures required by CMS in order to receive the highest payment possible under the Merit-Based Incentive Payment System (MIPS) Quality Payment System (QPP) requires monitoring of 4 performance categories: quality, improvement activities, advancing care Information, and cost.

How to submit specialty data, though?

A CMS-approved Qualified Clinical Data Registry (QCDR) is an entity that collects clinical data from an individual MIPS-eligible clinician, group, and/or virtual group and submits the data to CMS on their behalf for MIPS purposes.

Unlike other types of data submission methods, a QCDR reporting option is not limited to MIPS quality measures. The QCDR can develop and submit QCDR measures for CMS review and approval. A QCDR measure is a measure that isn’t in the annual list of MIPS measures for the applicable performance period, or a measure that may be in the annual list of MIPS measures but has major differences in how it’s submitted by the QCDR, according to a CMS fact sheet.

These QCDR measures are different because they are not contained in the annual list of MIPS quality measures, or it is on the annual MIPS list, but is substantially different or in how it is submitted.

CMS has approved about 150 QCDRs for 2018, and one of them is IntrinsiQ Specialty Solutions, a part of AmerisourceBergen, which recently joined the list.

IntrinsiQ is one of the largest providers of electronic health records (EHRs) for urologists, said Susan Weidner, senior vice president of analytics at IntrinsiQ Specialty Solutions, in an interview with The American Journal of Managed Care^®. And that makes it easy for their QCDR to lift and analyze data directly from the EHR and submit it to CMS on behalf of the provider, she said.

“With the shift to value-based care, specialty providers wanted new solutions, like earlier performance monitoring, centralized clinical quality of measures, and to start to expand that capability above and beyond the MIPS measures so that they represent what they do as specialty providers,” she said.

Oftentimes, she said, providers may not know how they are performing until the last quarter of the year, or maybe the last 4 months. The goal of IntrinsiQ is to give providers and practices information from the time they start using it, to give them time to adjust if something is flagged as an opportunity to improve—say, an issue with a physician or with a workflow.

That helps providers “ensure that they're getting the highest level of score possible,” Weidner said.

In addition to MIPS measures, IntrinsiQ provides quality measuring on 5 additional measures related to urology, such as prostate cancer and hypogonadism. During the review process with CMS to get the QCDR measure for hypogonadism approved, IntrinsiQ was able to make the case that CMS should look at not just serum testosterone, but a whole set of indicators.

In addition to getting speciality-specific measures cleared, the company also wants to be aligned to what some payers would like to see measured.

“The MIPS measures that are out there were intended for things that could be implemented by any provider,” she said. “The challenge is that if we’re really trying to use those to measure the quality of care, it’s not an accurate representation of what a specialty provider does, or the types of patients that they may be treating.”

For instance, she said, not all oncologists treat all oncology patients. And whether or not an oncologist or urologist provides immunizations may not be the most appropriate measure of quality.