Quality Measurement Task Force

2016 Physician Fee Schedule (PFS)

July 24, 2015

Cheryl Damberg, Co-ChairKathleen Blake, Co-Chair

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Membership

First Name Last name Member Type OrganizationCheryl Damberg Co-chair Senior Principal Researcher, Rand Corporation

Kathleen Blake Co-chair MD, AMALori Coyner Member Director of Health Analytics, Oregon Health

AuthorityFloyd Eisenberg Member MD, MPH, iParsimony, LLC

Joe Kimura Member Deputy Chief Medical Office, Atrius Health

Ginny Meadows Member VP, Regulatory Strategy, McKesson Corporation

Elizabeth Mitchell Member President and CEO, NHRIJason Mitchell Member MD, Chief Medical and Clinical Transformation

Officer for Presbyterian Healthcare Services

Sally Okun Member VP Advocacy, Policy and Patient Safety, Patients Like Me

Frank Opelka Member Medical Director of Quality and Health Policy, American College of Surgeons

Dan Riskin Member MD, MBA, FACS, and CEO and Founder of Vanguard Medical Technologies

David Lansky Member President and Chief Executive Officer, Pacific Business Group on Health

Radiology SMEs

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First Name Last name OrganizationCharles Truwit MD, Chief Innovation Officer and Chief of Radiology, Hennepin

Health System

Michael Mirro MD, Chief Academic/Research Officer, Parkview Mirro Center for Research and Innovation

Proposed QMTF Schedule

QMTF Call July 21st10:00 AM – 11:30 AM ET09:00 AM – 10:30 AM CT07:00 AM – 08:30 AM PT

QMTF Call July 24th2:30 PM – 3:30 PM ET1:30 PM – 2:30 PM CT

11:30 AM – 12:30 PM PT

QMTF Call July 30th2:00 PM – 3:00 PM ET1:00 PM – 2:00 PM CT

11:00 AM – 12:00 PM PT

Final QMTF Call August 4th 12:00 PM – 1:00 PM ET

11:00 AM – 12:00 PM CT9:00 AM – 10:00 AM PT

Presenting at HIT Policy Committee Meeting: August 11th, 2015

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2016 PFS Areas for Review

Task Force to Focus on:

1. Appropriate Use Criteria (AUC) for Radiology CDS

2. Revision of Certified EHR Technology (CEHRT) to require clinical quality measures (eCQM) reporting using CMS’ QRDA IG (for providers who choose to submit eCQMs)

3. Meaningful Use (MU) measure for Accountable Care Organizations (ACO)

PAMA Sec 218 directs the secretary to consider a variety

of qualified clinical decision support mechanisms,

including mechanisms within certified EHRs, which ordering

professionals must use to consult AUC when ordering

radiology images:

1. How are providers successfully using EHRs

and other health IT tools to consult clinical

decision support criteria today?

2. Could existing CDS criterion meet anticipated needs, and what are the key forthcoming

standards and certification criteria which may support

these processes in the future?

3. What are the key strategic considerations

ONC must address to ensure certified EHRs

support these activities?

Appropriate Use Criteria (AUC) for Radiology CDS Recap

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Appropriate Use Criteria (AUC) for Radiology CDS (cont.)

1. What are the key attributes/principles for how certified health IT (as a qualified clinical decision support mechanisms) should support the processes described in PAMA Sec 218 in the future? What is the vision of how HIT supports this ecosystem? Sample principles might include:• Ordering professionals should be able to use certified health IT to access AUC for

advanced diagnostic imaging seamlessly at the point of care.• Certified health IT should support access to AUC that is updated on a continuous

basis and delivered through certified health IT tools.• Certified health IT should enable users to easily switch between approved AUC

content providers.• Certified health IT should capture additional information about why AUC were

not followed to support quality improvement and provide meaningful performance feedback over time.

• Certified health IT should deliver actionable recommendations to clinicians based on third party data derived from AUCs.

• AUC should be available in standardized formats that can be consumed by any certified health IT application.

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Appropriate Use Criteria (AUC) for Radiology CDS (cont.)

2. What are the major strategic considerations for arriving at this vision? What are the key decision points around standards development and prioritization that ONC and CMS will need to focus on to realize this vision? Key considerations might include:• Currently available clinical decision support standards may not be ready to serve

these needs. How should ONC address future readiness of standards to support these processes? When should this be addressed?

• An API or a link to a hosted service embedded in the EHR may be preferable to or serve as a complement to a decision support standard. How should ONC frame and address the tradeoffs between these approaches? When should this be addressed?

• AUC in use today have not been developed with EHR implementation or certification standards in mind. How are AUC content providers likely to evolve to deliver standardized AUC that can be consumed using certified health IT?

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CY 2015 PFS Final Rule: Beginning in CY 2015, eligible providers (EPs) are not required to ensure that their CEHRT products are recertified to the most recent version of the electronic specifications for the CQMs. »EPs must still report the most recent version of specifications for the CQMs.

FY 2016 IPPS Rule:ONC proposed a certification criterion for “CQMs-report”. »This proposal would require that health IT enable users to electronically create a data file for transmission of CQM data in accordance with the Quality Reporting Document Architecture (QRDA) Category 1 and Category III at minimum.»As part of the “CQMs – report” criterion, ONC also proposed to offer optional certification for EHRs according to the “form and manner” that CMS required for electronic submission to participate in the EHR Incentive Programs and PQRS.

FY 2016 IPPS Rule:CMS stated they anticipate proposing to require EPs, eligible hospitals, and CAHs seeking to report CQMs electronically as part of meaningful use under the EHR Incentive Programs for 2016 to adhere to the additional standards and constraints on the QRDA standards for electronic reporting as described in the CMS QRDA IG. »CMS stated anticipating proposing to revise the definition of CEHRT to require certification to the optional portion of the 2015 Edition CQM reporting criterion in the CY 2016 Medicare Physician Fee Schedule.

Revision of CEHRT to require eCQM reporting using CMS’ QRDA IG (for providers who choose to submit eCQMs)

Overview

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Revision of CEHRT to require eCQM reporting using CMS’ QRDA IG (for providers who choose to submit eCQMs) cont.

To revise the CEHRT definition to require providers to possess technology that can report CQMs using industry standards (QRDA Cat I and Cat III) and in the form and manner of CMS submission (according to the CMS QRDA IG)• This would be optional for 2015-2017 and required for

2018 and beyond.

Advance Reading for Next Call

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• Members are welcome to view the following slides regarding the Meaningful Use measure

for ACOs in preparation of the next QMTF call.

Meaningful Use Measure for Accountable Care Organizations (ACOs)

• In the November 2011 final rule, CMS finalized one measure under the Care Coordination/Information Systems domain, the percent of PCPs within an ACO who successfully qualify for an EHR Incentive Program incentive (76 FR 67878).• CMS expanded it to include eligible professionals that qualified for payments to adopt,

implement, or upgrade EHR technology, in addition to those receiving a payment for meeting Meaningful Use Requirements, in order to include these participants in the measure.

• A notice of proposed rulemaking for “Stage 3” of the EHR Incentives program, released in March 2015 (80 FR 16731), and a related proposed 2015 Edition of ONC certification criteria (80 FR 16804), aim to support provider’s ability to exchange a common clinical dataset across the continuum of care.• In addition, ONC released a document entitled “

Connecting Health and Care for the Nation: A Shared Nationwide Interoperability Roadmap” which focuses on actions that will enable a majority of individuals and providers across the care continuum to send, receive, find and use a common set of electronic clinical information at the nationwide level by the end of 2017.

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Background

Meaningful Use Measure for Accountable Care Organizations (ACOs) (cont.)

CMS is seeking early comment for the 2017 performance year:How this measure might evolve in the future to ensure providers are being incentivized

and rewarded for continuing to adopt and use more advanced health IT functionality and broadening the set of providers across the care continuum that have adopted these tools.

1. Should this measure be expanded in the future to include all

eligible professionals, including specialists, consistent with an

updated definition of eligible professionals in

the Medicare Access and Chip Reauthorization

act?

2. How could the current measure be updated to reward providers who have achieved higher levels of Meaningful

Use?

3. Should we substitute or add another measure

which would focus specifically on the use of

health information technology, rather than

meeting overall MU requirements, for

instance, the transitions of care measure required

for the EHR Incentives program?

4. What other measures of IT-enabled processes would be most relevant

to participants within ACOs? How could we seek to minimize the

administrative burden on providers in collecting

these measures?

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