How Can ACOs Master APP Reporting for Performance Year 2025?

January 21, 2025

With the mandatory implementation of Alternative Payment Model Performance Pathway (APP) Reporting set to begin in Performance Year 2025, it’s crucial for Accountable Care Organizations (ACOs) to start preparing now. This shift necessitates reporting quality across all beneficiaries, which requires thorough preparation and strategic planning. If your ACO hasn’t started yet, there’s no need to panic—there is still time to get on track.

Key Steps and Considerations for ACOs

Finalizing Your Reporting Plan

The initial and most essential step is to ensure your ACO finalizes its plan by determining the optimal reporting method. Understanding the best approach to perform APP Reporting involves selecting from three options: Electronic Clinical Quality Measures (eCQMs), Merit-based Incentive Payment System Clinical Quality Measures (MIPS CQMs), and Medicare Clinical Quality Measures (Medicare CQMs). Each of these approaches comes with its own set of advantages and challenges, and the choice is not automatic.

It will depend heavily on factors such as your participating physician practices, their Electronic Health Records (EHRs), and your data needs. Making an informed decision requires a comprehensive evaluation of each option’s capabilities and suitability for your specific organization. It is essential to not only understand the immediate requirements but also anticipate future needs and potential growth areas for your ACO. A well-thought-out plan will set the foundation for successful APP Reporting, ensuring your organization remains compliant and efficient in its operations.

Evaluating Electronic Clinical Quality Measures (eCQMs)

Advantages of eCQMs

The primary reason many organizations prefer eCQMs is that one electronic source document, a QRDA-I, can capture both the denominator and numerator of measures. If your system is capable of generating a QRDA-I, it simplifies the reporting process for the organization. This method can streamline data collection and ensure consistency across different practices within the ACO. Utilizing a standardized data format helps in maintaining uniformity and accuracy, which is critical for quality reporting.

Furthermore, eCQMs can be integrated seamlessly into existing workflows, minimizing disruptions and allowing for real-time monitoring and adjustments. By leveraging electronic data capture, ACOs can reduce the manual workload and potential for human error, thus increasing the overall efficiency and reliability of the reporting process.

Challenges of eCQMs

Not all EHRs can generate a QRDA-I. Each individual practice EHR must be capable of producing this specific data format. Furthermore, multi-EHR ACOs face the challenge of ensuring that all EHRs can export a QRDA-I. Additionally, patient data from QRDA-I files must be aggregated, and patients must be de-duplicated through patient matching and integration of data. This can be a complex and resource-intensive process, requiring significant coordination and technical capability.

The implementation of eCQMs also involves substantial initial investments in technology and training. ACOs must be prepared to allocate resources towards upgrading their EHR systems and training their staff on new workflows. Despite these challenges, the benefits of adopting eCQMs can outweigh the initial hurdles, provided that the organization is committed to long-term improvements in data quality and reporting accuracy.

Comparing MIPS Clinical Quality Measures (MIPS CQMs)

Advantages of MIPS CQMs

MIPS CQMs offer higher flexibility in data source formats for both numerators and denominators. Your ACO can aggregate QRDA-Is, flat files, and any external data backed by the clinical record. This flexibility is advantageous for other ACO purposes such as population health, cost management, analytics, and health equity. The ability to use various data sources can help ACOs tailor their reporting to their specific needs and capabilities.

In addition to streamlining the reporting process, MIPS CQMs can provide valuable insights into patient outcomes and practice performance. ACOs can leverage this data to identify areas for improvement, track progress over time, and implement targeted interventions. By utilizing a more diverse data set, organizations can achieve a more comprehensive understanding of their patient population and make informed decisions to enhance care delivery.

Challenges of MIPS CQMs

While EHRs must be able to produce reports for their systems, the initial effort involves ACO or practice staff generating data files, which requires periodic involvement thereafter. This ongoing effort can be a burden on staff, particularly in larger ACOs with many participating practices. Ensuring data accuracy and consistency across different sources can also be challenging, requiring robust data management and validation processes.

In addition to the technical challenges, MIPS CQMs necessitate a coordinated approach to data governance and quality assurance. ACOs must establish clear protocols for data collection, storage, and reporting to maintain the integrity of their metrics. This may involve additional training for staff and ongoing monitoring to ensure compliance with established standards. Despite the potential difficulties, the flexibility and comprehensive nature of MIPS CQMs make them a viable option for many ACOs.

Exploring Medicare Clinical Quality Measures (Medicare CQMs)

Advantages of Medicare CQMs

This method is based on the goal of limiting ACO workload in data aggregation. CMS provides quarterly lists of patients eligible for measures based on claims. This can reduce the burden on ACOs by providing a clear starting point for data collection and reporting. It can also help ensure that all eligible patients are included in the reporting process. Additionally, the structured approach of Medicare CQMs aligns closely with the claims data already being used by many ACOs for other purposes, facilitating smoother integration.

By leveraging claims data, ACOs can gain a broader view of patient interactions with the healthcare system, identifying patterns and trends that might not be evident through other data sources. This comprehensive perspective can inform strategic decisions, such as resource allocation, care coordination, and patient outreach efforts. The reliance on claims data also enables ACOs to track long-term outcomes and measure the impact of their interventions over time.

Challenges of Medicare CQMs

ACOs must still validate eligibility with their data, meaning they still need to aggregate data from practice management systems to verify patient coverage, visits, and diagnoses. This method, while reducing some costs, can come with a higher staff burden due to manual lookup and submission of values. Ensuring the accuracy and completeness of the data can be time-consuming and labor-intensive.

Moreover, the manual nature of data validation can lead to delays and potential errors, impacting the overall efficiency of the reporting process. ACOs must implement rigorous quality checks and validation protocols to maintain the integrity of their data. Despite these challenges, Medicare CQMs offer a pragmatic approach that can be particularly beneficial for organizations with limited resources or those in the early stages of implementing a comprehensive reporting strategy.

Deciding on the Optimal Method

Factors to Consider

The best method for performing APP Reporting will depend on several vital factors, including the structure of your ACO, the capabilities of your existing EHR systems, and your long-term goals. For cost-conscious ACOs, the Medicare CQMs might be the best initial choice, though it may involve more work in the long run as the number of measures grows. For data-driven ACOs, organizations focused on outcomes and health equity may start with Medicare CQMs but should eventually shift to eCQMs or MIPS CQMs to leverage more comprehensive data sets.

Ultimately, the decision should be informed by a thorough analysis of your ACO’s current capabilities and future aspirations. Engaging stakeholders from across the organization, including clinicians, IT specialists, and administrators, can help ensure that all perspectives are considered. By adopting a collaborative approach, your ACO can select a reporting method that aligns with its strategic objectives and operational realities.

Strategic Planning for the Future

Regardless of the chosen method, it’s essential to recognize that CMS aims to require more measures and (interoperable) digital measures in the future, leading to a more robust data solution. Therefore, taking early steps towards building a capable and comprehensive reporting strategy is crucial for long-term success. By beginning this preparation now, ACOs can ensure they are well-equipped to navigate the upcoming changes in APP Reporting.

Investing in the necessary technology, training, and infrastructure will not only facilitate compliance with APP Reporting requirements but also position your ACO as a leader in quality care delivery. By proactively addressing potential challenges and leveraging available resources, your organization can create a sustainable and effective reporting framework that supports continuous improvement and patient-centered outcomes.

Conclusion

With the mandatory implementation of Alternative Payment Model Performance Pathway (APP) Reporting set to begin in Performance Year 2025, it’s essential for Accountable Care Organizations (ACOs) to start preparing now. Transitioning to this new model requires comprehensive planning and a strategic approach to ensure quality reporting across all beneficiaries. This change aims to enhance the quality of care and accountability within ACOs, but requires significant groundwork and adjustments to current practices. If your ACO hasn’t started the preparation process yet, there’s no need to panic—there’s still adequate time to get things in order. However, the sooner you begin, the more manageable the transition will be. By carefully assessing your current reporting systems, identifying any gaps, and developing a detailed action plan, your organization can align seamlessly with the new APP reporting requirements. It will be important to educate your team on these changes, invest in necessary technological upgrades, and perhaps seek external expertise to ensure compliance and improve overall care quality.

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