What is a Medicare CQM?

In 2024 PFS Proposed Rule CMS threw a curveball and added a brand-new collection type to the mix. Their hope is that this will help alleviate ACO’s concern about transitioning to an all payer/all patient reporting model.

What is a Medicare CQM?

A Medicare CQM is essentially a MIPS CQM except it only reports on an ACO’s Medicare fee-for-service beneficiaries instead of all payer/all patient.

Medicare CQMs are proposed to be available in the Quality Payment Program (QPP) starting with the 2024 performance year. This collection type is only available to MSSP ACOs who are reporting under the APP reporting framework. The same three required measures are available as eCQMs, CQMs, or Medicare CQMs. The measures are:

1. Quality ID: 001 Diabetes: Hemoglobin A1c (HbA1c) Poor Control
2. Quality ID: 134 Preventive Care and Screening: Screening for Depression and Follow-up Plan
3. Quality ID: 236 Controlling High Blood Pressure

You may choose to submit different collection types for one submission.

Keep in mind, CMS already indicated in their proposed rule that Medicare CQMs are not a long-term solution, and they want ACOs to work toward submitting either eCQMs or CQMs.

“Our long-term goal continues to be to support ACOs in the adoption of all payer/all patient measures. …Separately, we may specify higher standards, new measures, or both – up to and including proposing to sunset the Medicare CQM collection type in future rule-making.” - CMS PFS Proposed Rule

How will CMS calculate an ACO’s Medicare beneficiaries with Medicare CQMs?

CMS is going to calculate your beneficiaries differently than the way they usually assign beneficiaries to an ACO. Assigned beneficiaries will instead align with how beneficiaries are assigned under the MIPS CQM specification.

For instance, you are used to a beneficiary being assigned based on terms like “primary care services” and “assignment window.” That’s not how Medicare CQMs will assign beneficiaries for APP reporting. They will use the terms “claims” for primary care services and “measurement period” for assignment window.

A Medicare fee-for-service beneficiary is a patient who either:

Meets the criteria for a beneficiary to be assigned to an ACO
AND
Had at least one claim with a date of service during the measurement period from an ACO professional who is an Eligible Clinician that you are responsible for reporting for under QPP.

OR

A patient who meets the criteria for a beneficiary to be assigned to an ACO because the beneficiary designated an ACO professional participating in an ACO as responsible for coordinating their overall care.

CMS will provide a list of eligible beneficiaries to your ACO before the reporting period starts but they indicated it may not be the full list of beneficiaries you have to report for, and therefore; you are responsible for getting and reporting on the full list of eligible beneficiaries.

Other notes about Medicare CQMs

Incentive for eCQM/CQM Reporting

CMS is not extending the eCQM/CQM incentive to the Medicare CQM collection type. That means if you choose to report Medicare CQMs you must achieve a 40^th percentile score across all three required measures.

Furthermore, CMS will calculate 2024 and 2025 benchmarks for the Medicare CQMs based on performance period benchmarks. They will transition to historical benchmarks in 2026 and subsequent years.

This means that you will not know the benchmarks during the performance period. So, while you must achieve the 40^th percentile (benchmark) for each of the three measures, you aren’t going to know what to shoot at.

If you choose to submit eCQMs/CQMs in 2023 and/or 2024 you only have to achieve the 10^th percentile on one outcome measure and the 30^th percentile on another measure and you can share savings at the maximum rate.

Data Completeness Threshold

CMS also noted that the Data Completeness Threshold is applicable to Medicare CQMs as well. For 2024 – 2026 the Data Completeness Threshold is 75% and then increases to 80%. But that doesn’t mean you only need data from 75% of your practices. No. You need data from 100% of your practices and Eligible Clinicians.

“The ACO’s aggregated ACO submission must account for 100% of the eligible and matched patient population across all ACO participants.” - CMS PFS Proposed Rule

The threshold applies when an abstractor goes through the denominator-eligible population and can’t make a determination because of missing data.

Read more: What is data completeness in MIPS?

Promoting Interoperability Requirements

Starting in 2024, all MSSP ACOs must adhere to the Traditional MIPS category requirements for Promoting Interoperability (PI). That means that 100% of your Eligible Clinicians must be on a Certified Electronic Health Record Technology (CEHRT).

In the past you may have been able to attest that between 50 – 75% of your clinicians were on CEHRT. That is no longer acceptable. By 2024 you must have all of your practices off paper.

You may submit the PI category:

At an aggregate level on behalf of 100% of your Eligible Clinicians

OR

100% of your Eligible Clinicians may submit as an individual or part of a group submission separately.

How to Get Started With eCQM/CQM/Medicare CQM Reporting

ACOs must learn to juggle multiple, disparate EHRs and data collection methodologies. Developing a cohesive data aggregation system is going to be a major undertaking. Your senior leadership, quality management, and information technology teams need to start planning what that looks like for your ACO now.

The most important thing you can do right now is understand what your data landscape looks like. Here are a couple of questions you should know.

1. Which practices are on which EMRs? Make a list.
2. How many instances of each EMR vendor do you have?
3. Do you have any practices still on paper charts? (<<If so, you cannot report to CMS.)
4. How many practices are on less common EMRs?
5. Can every single practice generate a QRDA I file (<<Applicable for eCQMs. Especially focus on those practices with less common EMRs.)
6. Do you capture CPT II (G codes) in a database for all practices? (<<Applicable for MIPS CQMs/Medicare CQMs.)

This information will help you to choose whether you want to submit eCQMs, MIPS CQMs, and/or Medicare CQMs. It will also inform you as to whether you must set up conversations with any practices not able to provide your group with what you need.

How Long Will the Data Acquisition Process Take?

This is completely dependent upon your organization set up. For most of our clients, we tell them to estimate a 6–8-month implementation time before you start to see any meaningful data.

More Resources to Prepare Your ACO For What’s Next

At Medisolv, we offer so much more than quality software and start-to-finish submissions management. We’re the quality improvement partner committed to deciphering and anticipating CMS’s regulatory changes for you—so that you can keep your organization ahead of the curve.

Final Thoughts: Don’t Wait

Yes, it’s true. CMS has offered your ACO a relief valve to help transition you to eCQM/CQM reporting. But CMS also indicated that these measures won’t be around forever, and they want you to move to an all payer/all patient reporting method.

While Medisolv can help you with any of the three collection types, we suggest you consider your ACO’s long-term goals and the resources and costs available to you now and in the future as you make your decision.

It's in your best interest to start looking at your data through the all-patients, all-payers, all-practices lens now. It is the key to unlocking so many other patient care goals for you, including improving population health, reducing health care costs, and advancing health equity. For too long, the CMS Web Interface had made quality reporting a box that organizations had to check. It’s time now for organizations like yours to lead the charge to elevate the role of quality data in patient care. Together, we have the power to put quality data to good use.

Check out some of our additional resources now:

• eBook: CMS Web Interface Transition Guide
• Article: 2023 QPP Requirements
• On-Demand Webinar: Preparing your ACO for APP Reporting