Frequently Asked Questions / Concerns About the APM Performance Pathway (APP) Data Requirements
What are the CMS data requirements for MSSP ACOs for the new APP?
The new APP requires MSSP ACOs to send data for 3 quality measures for all ACO participants and all payors in order to meet shared savings requirements. In addition, MSSP ACOs are evaluated on 2 administrative claims measures and a patient care survey.
How is CMS measuring the ACO’s quality performance now?
Currently, CMS requires MSSP ACO’s to send quality data for 10 quality measures on a sample of 248 Medicare patients.
What are the 3 APP quality measures?
The 3 measures are as follows:
What data is required for the 3 APP measures?
Participating ACO clinicians will be required to send patient eligibility and compliance data in the form of EHR quality reports (QRDAIs) for those practices with the required functionality or billing reports and / or patient lists for those who do not have the required EHR functionality.
How much effort will be required for my practice to comply with the data requests?
MD Interactive and TMIP will request reports minimally at the beginning of the year and at the end of the year. The first report might require some dedicated effort as you become familiar with the reporting functionality of your EHR platform. We will provide you with general instructions and training but because each data platform is slightly different, some collaboration with your EHR support team might be needed initially.
What if the APP measures do not primarily apply to my specialty?
Although we recognize that the APP measures do not primarily apply to all specialties, all ACO participating clinicians are required to participate and send data for this program. Patient data will be aggregated, and compliance will be evaluated at the ACO level by CMS, not at the individual clinician or practice level. It is not uncommon for practice level EHR reports to show a 0% compliance rate for some measures if they are not of primary importance to a specialist.
Is it possible that I do not have patients eligible for the 3 APP measures?
All clinicians with office visits will minimally have patients eligible for the Screening for Depression measure, as identified by CMS measure specifications.
What will the ACO do with the data I send?
After a thorough vetting process, we chose MDinteractive, a Boston-based CMS Qualified Registry to help us comply with CMS’ reporting requirements. MDinteractive will de-duplicate and aggregate the data we send, will ensure that we are complying with CMS requirements, and will submit our data to CMS when it is due.
What data will be sent to CMS?
Aggregated ACO performance metrics for the 3 APP quality measures will be sent to CMS; CMS will not receive individual practice, clinician, or patient information.
Is it easier to meet Medicare requirements outside of the ACO?
Clinicians who see Medicare patients and are not part of an ACO generally have more stringent data requirements through the Merit-based Incentive Payment System (MIPS). Non-ACO clinicians are required to submit data for 6 Quality measures, instead of 3.
