- The National Committee for Quality Assurance (NCQA) recently made nearly a dozen recommendations to CMS on the next iteration of the Quality Payment Program (QPP).
The recommendations came in response to a request for comment regarding the QPP proposed rule released in June.
While the organization has called for a host of changes to the program, it did commend CMS for its efforts to simplify virtual groups in the coming year. “This is a key step toward helping small practices advance toward accountable, team-based, patient-centered care models,” the NCQA letter to CMS stated.
However, NCQA requested CMS provide further incentive for clinicians to create virtual groups.
“We urge you to provide bonus points as incentive for clinicians to join Virtual Groups,” it continued. “We also urge you to encourage, rather than prohibit, low-volume clinicians’ participation in Virtual Groups.”
The organization also included suggestions regarding the status of its Patient-Centered Connected Care (PCCC) Program.
The committee applauded the organization for including PCCC as an Improvement Activity in MIPS with Advancing Care Information (ACI) credit for its use of health IT, but recommended PCCC receive high-weighted improvement activity status due to the program’s focus on care coordination, evidence-based decision support, expanded access, and culturally and linguistically appropriate services.
Similarly, NCQA suggested CMS provide Advancing Care Information auto-credit to Patient-Centered Medical Homes (PCMHs) and Patient-Centered Specialty Practices (PCSPs) due to their use of health IT standards.
“ACI auto-credit would reduce unnecessary burden for clinicians who have already completed the rigorous PCMH or PCSP recognition process,” NCQA President Margaret O’Kane argued.
In addition, the committee recommended CMS take a more comprehensive approach to deciding which measures are topped out.
“Currently, clinicians choose which measures they report and how they report them,” O’Kane explained. “This voluntary reporting may lead clinicians to ‘cherry pick,’ reporting only measures on which they perform best or only on a sample of the relevant population.”
“An accurate picture of topped out measures requires more universal data collection with mandatory reporting on a clinician’s entire population,” she added.
NCQA submitted additional recommendations about the MIPS performance threshold, improvement activities, virtual groups, quality measure data completeness, improvement plans, and reporting mechanisms.
On the subject of MIPS performance thresholds, NCQA expressed its support for the proposal to establish a 15-point threshold for avoiding performance penalties in 2018. However, the committee requested CMS increase the threshold in the future to increase the likelihood that appropriate incentives will be given to clinicians to improve performance on MIPS measures.
Included among its recommendations for improvement activities, NCQA advised CMS to offer full auto-credit to any practice that achieves NCQA Recognition by December 31 of any performance year.
NCQA itself requires practices seeking PCMH and PCSP recognition to perform improvement activities as mandated by CMS for a minimum of 90 days, warranting auto-credit. “This policy should extend to any other approved PCMH programs that use a 90-day lookback period,” wrote the committee.
As for reporting mechanisms, NCQA recommended CMS develop a transition plan to move toward exclusively accepting data from EHRs with proven abilities to produce valid measurement data, including EHR systems that have NCQA eMeasures Certification.
“This is key to ensuring that Medicare is paying bonuses and penalties based on the most valid, reliable data available,” wrote the committee.
NCQA also submitted recommendations for third-party data intermediaries, risk adjustment, bonus points, and alternative payment models.
CMS is accepting comments regarding the QPP proposed rule until August 21.