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NQF Comments on Merit-Based Incentive Payment System Measures

NQF has made recommendations for the Merit-Based Incentive Payment System and other programs involving quality reporting.

By Kyle Murphy, PhD

The partnership formed by the National Quality Forum has recommended changes to quality measures to be used in the Merit-Based Incentive Payment System which will in turn have consequences for eligible providers and meaningful use requirements.

Last week, NQF released its guidance on quality measures to be used as part of MIPS and other healthcare programs.

As noted in NQF's Measure Applications Partnership (MAP) analysis of the proposed quality measures, the group detailed where the EHR Incentive Programs will fit into quality improvement landscape driven by the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015:

"Under the MIPS program, each eligible professional or group practice will be assigned a composite performance score based on four categories: quality, resource use, clinical practice improvement activities, and meaningful use of certified electronic health record (EHR) technology," states the MAP final report. "Eligible professionals’ payments will then be adjusted up or down (or not at all) based on comparison of their composite scores to a performance threshold."

So it is that the EHR Incentive Programs and their meaningful use requirements will become a subcomponent of a much larger quality improvement program.

Through the combining of these quality reporting programs, which includes the Physician Quality Reporting System (PQRS) as well, the Centers for Medicare & Medicaid Services (CMS) intends to move toward greater alignment of quality measures to reduce reporting burdens on providers and increase the "comparability and transparency of healthcare information."

Problems, however, remain quality reporting improvement, the MAP report reveals.

For one, measure gaps still persist despite this effort at alignment quality measures and programs:

In particular, MAP members noted the need for patient-centered measures, including patient-reported outcome measures, functional status measures, care coordination measures, and measures that incorporate patient values and preferences. MAP noted that the principle of patient preference could apply not only to new measures, but also to existing measures, which could potentially be modified to include outcomes or processes that reflect patient preferences and shared decisionmaking

According to the group convened by NQF, these gaps highlight disparities between how providers and patients view clinical success, with insufficient weight being placed on patient perspectives.

Additionally, the MAP final report shines light on the need for evaluating the quality of team-based care:

The importance of developing measures of team-based care was also a recurring theme. MAP members suggested that the healthcare system needs to do better at identifying patients who are in need of care, defining what good care looks like for them, and leveraging both team-based approaches and the overall resources of the health system to provide that care.

Another area of concern raised by the NQF MAP was the impact of sociodemographic status on quality measure results:

MAP members noted that taking account of whether providers are caring for high-risk populations is important to providers—from both a clinical and a sociodemographic standpoint. It is important for providers who want to ensure a level playing field for performance measurement, and it also is important to patients who want to know which providers are taking good care of high-risk populations. MAP observed that these considerations may become increasingly important in the context of patient-reported outcomes.

Also a sticking point for the group was balancing the specificity and generalizability of quality measures:

MAP members agreed that having a limited set of broadly applicable measures is an important goal for federal programs, because such a measure set should help to ensure alignment, reduce measurement burden for providers, and increase the comparability of performance across contexts (e.g., different providers and settings). However, MAP members acknowledged that the practices of some physicians (e.g., ophthalmologists, oncologists) can be very highly specialized, and that correspondingly specialized measures are needed to evaluate the quality of care appropriately.

More fuel was added to the debate over quality reporting requirements with the recent revelation that physicians spent an estimated $15.4 billion annually completing quality reporting activities for Medicare, Medicaid, and private insurers.

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