eCQMs vs Medicare CQMs: Which Is Better for ACOs?

eCQM or not eCQM: it’s the question on the minds of many ACO quality leaders as we enter the Quality Payment Program’s (QPP) 2025 performance year. After all, this will be the first year without the CMS Web Interface. And, if this year’s PFS proposed rule goes through as planned in November, it will also be the first year without traditional CQMs as a reporting option.

That leaves ACOs with just two quality measure types to choose from in 2025: eCQMs or Medicare CQMs. So, which one is right for your ACO?

Spoiler alert: it’s probably not Medicare CQMs

Before you make your decision, it’s important to understand why CMS is whittling down your options. As you’ve probably heard more than a few times, CMS is on a mission to shift to an all-digital, “Universal Foundation” approach to quality measurement—and it considers eCQMs to be the cornerstone of this new approach. (Learn more about CMS’s vision for a Universal Foundation measure set here.)

But CMS also knows how long it takes to change hearts, minds—and ACO-wide systems and processes. And that’s why CMS first “gifted” us with Medicare CQMs in the 2024 performance year. Medicare CQMs are intended to be a transition measure type while ACOs collectively learn how to embrace and adopt digital quality measurement. They are not intended to be a long-term solution.

Thus, by sticking with Medicare CQMs, you are only delaying the inevitable. You will still have to make the switch to eCQMs at some point in the not-too-distant future. And, here at Medisolv, we always recommend getting a head start on future requirements whenever CMS gives you the opportunity to do so.

But that’s hardly the only reason why you should choose the eCQM path now. Here are three more reasons to consider...and the first one is a big one, so bear with us.

1. Medicare CQM data collection is a lot harder than it sounds

Just like us, you probably shuddered when you first heard the words “all patients, all payers” attached to the eCQM requirements. But it’s imperative that we closely examine the Medicare CQM data collection requirements before rushing to judgment. Let’s break them down:

• With Medicare CQMs, you only have to submit data on 75% of your Fee For Service (FFS) Medicare beneficiaries to meet your data completeness and aggregation requirements. Sounds less painful than all patients, all payers so far...
• Plus, CMS will send you a list of your eligible FFS beneficiaries quarterly. Each list is cumulative (year to date) and updated to reflect the most recent quarter’s data. Ok, that’s helpful...
• BUT...as with all things claims-data-related, you won’t be able to rely on these lists in a timely fashion. For example, CMS has promised to deliver the Q4 lists for performance year 2024 in February 2025—giving ACOs just one month to work off of them before 2024’s March 2025 reporting deadline.
• AND...these lists will only cover the basics, including the FFS patient’s age, diagnosis, and encounter information. You will not be able to determine, from the lists alone, which measure populations (if any) a patient qualifies for.
• AND...the lists will not have been de-duplicated or cross-checked to account for how many providers in your ACO a patient may have seen over the course of a performance year and how those interactions may have impacted a patient’s measure eligibility.
• AND...these lists will not have taken into account each patient’s medical history, including care received outside of your ACO, which may exclude a patient from a measure.

This means you will have to go through the extraordinarily complex and labor-intensive process of manually:

• Reviewing CMS’s lists against your own data to ensure all your FFS patients are accounted for
• Cross-checking each and every encounter with each and every FFS patient across your entire ACO to determine if and where they belong in your Medicare CQM measure set
• Double-checking each FFS patient’s record to ensure there are no codes or diagnoses that were originated from outside your ACO that may or may not impact their inclusion/exclusion from a measure
• And finally de-duplicating the list to ensure a clean data set.

Keep in mind that, while there were only three APP quality measures you’re required to report in 2024, you will have to go through this patient-matching process for five quality measures in 2025, six in 2026, and eight in 2028—assuming that the APP Plus Quality Measure Set that's laid out in the 2025 PFS proposed rule goes through.

*Finalized requirement

Clearly CMS realizes that this is the stuff of quality leaders’ nightmares, so it has released a toolkit for screening all FFS patients in order to develop your measure populations, as well as a Medicare CQM Checklist to help you keep track of it all. But just one look at the toolkit should help you understand just how cumbersome and prone-to-error this process still is:

We say, save yourself the data aggregation headaches and opt for the easier solution: eCQMs. The beauty of eCQMs lies in the power of its data source: the QRDA I files you extract from your EHR(s). QRDA I files have built-in algorithms to handle all the data complexity for you, even at the massive all-payer, all-patient level. Patient data will be collected, de-duplicated, and assigned to the appropriate measures for you—no manual labor or risk of human error involved.

Now, admittedly, getting your entire ACO up and running on QRDA I files is not a quick and easy feat. But with the right people and commitment, you can get there: see how one ACO successfully wrangled the QRDA 1 process here.

2. Medicare CQM performance standards are more challenging to meet

To encourage more ACOs to make the switch to eCQMs, CMS intends to continue offering its eCQM Reporting Incentive in 2025 and beyond. Under this incentive, ACOs can qualify for maximum shared savings by achieving just two scoring benchmarks:

• At or above the 10th percentile of the benchmark on at least one of the four outcome measures in the APP Plus quality measure set; and
• At or above the 40th percentile of the benchmark on at least one of the remaining measures in the APP Plus quality measure set.

There’s just one catch: the incentive only applies if you report and meet the data completeness requirements for all of the eCQMs in the APP Plus quality measure set. The incentive does not apply to ACOs that report a combination of eCQMs/Medicare CQMs or report only Medicare CQMs.

Again, we believe the juice is worth the squeeze. That’s because, by comparison, CMS has set a more challenging benchmark for everyone else. If ACOs choose to report Medicare CQMs instead of eCQMs, CMS is proposing a single—and more challenging—performance standard: you must achieve a health-equity adjusted score that is in the 40^th percentile or higher across all MIPS Quality performance category scores.

3. Medicare CQMs are not eligible for the Complex Organization Adjustment

In the latest proposed rule, CMS is proposing adding a Complex Organization Adjustment to the 2025 performance year and beyond, to account for all the organizational complexities ACOs face when reporting eCQMs. In short, CMS recognizes that, as we evolve towards a more robust APP Plus quality measure set and, ultimately, the Universal Foundation, ACOs will be “required to report on a larger measure set than other eCQM reporters” and wants to offer some scoring relief to counterbalance your effort.

If finalized in November, here’s how the Complex Organization Adjustment will work starting in 2025:

• You can earn one bonus measure achievement point for each eCQM you submit in a performance year.
• Each eCQM you submit must meet CMS’s data completeness and case minimum requirements to earn one bonus point.
• Your Complex Organization Adjustment may not exceed 10% of the total available measure achievement points in the quality performance category. CMS has ensured this by capping each eCQM’s total possible measure achievement points (bonus points and all) at 10 points.

Needless to say, if you choose to report Medicare CQMs you will not qualify for these bonus points.

More tools to help you make the right call

From all those data aggregation man-hours to the missed bonus points and reporting incentives, your ACO needs to ask itself: what will Medicare CQMs really cost you? A simple cost-benefit analysis may reveal the diving headfirst into eCQMs is not as bad as you think.

No matter which path is right for you, Medisolv is here to help you every step of the way. Our all-in-one APP Reporting Package for ACOs can help you take control of your eCQMs, Medicare CQMs, or both. And if you’re still undecided, be sure to check out our other resources designed to help you make sense of your APP reporting requirements:

• Webinar: Preparing Your ACO for APP Reporting
• Webinar: eCQMs 101 for ACOs
• Download: CERHT Compliance Checklist for ACOs
• Case Study: Taking the ACO Leap into eCQMs - The Secrets to Success