Participation in pay-for-performance plans like MACRA’s Quality Payment Program (QPP) poses new challenges for resource-strapped healthcare organizations. Many provider sites lack the time and technical expertise needed to retool their EHR implementation to document new metrics under value-based reimbursement models like the Merit-based Incentive Payment System (MIPS).
Nonetheless, that is precisely what clinicians must do to deliver on quality reporting requirements. When using EHR documentation tools, many factors must be considered for a provider to get credit on having met clinical quality measures (CQMs). How that information gets stored in the EHR directly affects reporting. Many healthcare organizations are finding that customizing an EHR to recognize when a measure has been met—preferably in a manner that poses as few interruptions to patient engagement as possible—is easier said than done.
Overcoming EHR Limitations
Many outpatient and inpatient settings still struggle with common EHR data management headaches. As clinicians bring new quality measures into the EHR, those underlying data management issues can foil even the best-laid reporting plans.
Discrete Data Capture
The push to better document clinical quality is causing a transition in EHRs to focus more on structured or discrete data that is easier to trend over time. Unfortunately, many healthcare providers still receive patient data from healthcare affiliates via fax. Those faxed documents show up as attachments in the patient chart and are not fully integrated into the patient data file. If that information was sent via HL7 interface instead, details on the care rendered by that hospital or other healthcare entity would flow into the EHR as discreet data variables. For many providers today, capturing that information in a manner that makes it usable in reporting and analytics still requires timely, manual data entry.
Documentation and Data Consistency
Provider sites with multiple clinicians may also encounter issues related to the slightly different way that each EHR user documents care. MIPS and other quality programs require consistency and a high degree of specificity in clinical documentation. If a clinician does not get diagnosis specifics into the patient chart, that patient may not be included in the CQM calculation they need to be included in. Many clinicians are having to modify their documentation process during patient encounters so they and the staff can capture all the necessary information in the EHR.
Clinical documentation will have even bigger repercussions under the Cost component of MIPS, which is slated to be factored into performance scores in coming years. Take, for example, a patient that is in for the flu. That patient has a certain anticipated cost impact (the average Medicare spending per beneficiary), calculated based on past medical history and services rendered. If a patient goes to a physician and has the flu but also has diabetes, heart failure, and asthma, that flu patient is probably going to cost more to care for. If the physician only submits the flu diagnosis and fails to document patient co-morbidities then the healthcare organization will not get the same allowance under the MIPS Cost category and could be labeled as “higher cost” than a comparable provider encounter for a patient that required fewer resources to care for.
Clinicians, coders, and staff need to make a mental transition away from “we’re submitting claims” to “we’re submitting data” to better serve clinical reporting initiatives and patient care analysis.
Making Informed CQM Selections
Beyond adapting to new data management processes, clinicians reporting under value-based programs also have a great deal to learn as they layer in additional quality measures under MACRA. One of the biggest challenges clinicians and administrators face is selecting the best measures for their specific healthcare organization. With limited spare time on their hands, many healthcare teams are leaning on outside expertise to help them evaluate the implications of various measure selections.
Measures Without Benchmarks
Many quality measures under MACRA are carry-overs or “relics” from other reporting programs. For these CQMs, providers can look to prior performance averages to evaluate the likelihood of success should the healthcare organization elect to report on those measures. That data does not exist for some CQMs, which are referred to as “measures without benchmarks.” On measures that have no benchmark data available, providers will be limited to a maximum of three reporting points instead of the ten points available on measures with benchmarks established.
To further complicate things, details on the availability of some benchmark data will not be calculated until after the March 2018 QPP reporting deadline. Providers may wish to further diversify or report on additional measures that could help offset low point earnings on measures without benchmarks.
Topped Out Measures
Another CQM caveat that providers should be aware of relates to “topped out” measures. These relic measures from other reporting programs are very engrained in many healthcare settings. Medication reconciliation, for example, was a requirement under Meaningful Use. Widespread adoption and universally high compliance rates on that measure makes it more difficult for clinicians to out-perform peers. Achieving maximum points on such measures requires a perfect or near-perfect score.
Keep average performance thresholds in mind when evaluating CQM selections, not just the healthcare entity’s individual performance track record. Look at a broader set of measures to maximize MIPS score potential. Clinicians could earn more points by scoring 70 percent on a non-topped out measure than they would earn scoring 95 percent on a topped out measure. Some topped out measures will likely be eliminated in future years to help diversify CQMs, as was the case under Meaningful Use.
Understanding the intricacies of CQM selection and EHR data management will be vital to success under value-based payment programs. Healthcare administrators and clinicians who proactively work to better understand the impact of various measures and streamline EHR processes will be best positioned to maximize program incentives.
Does your organization have the resources it needs to successfully navigate MIPS? Learn how Pivot Point can help with your value-based strategy.
