CMS Is Asking for Digital Quality Measures, and AAOS has Answers
Recently CMS released proposed rules in the May 10, 2021 Federal Register that included a Request for Information (RFI) on Digital Quality Measures (dQMs) whose scores would be electronically collected and reported. The goal of this blog is to break down what CMS is looking for into bite-sized pieces and the response of AAOS. It’s one of the more technical pieces we’ve written here at CODE, but we want to make sure we didn’t leave out any of the meat and potatoes that will be relevant to you and your organization. If you are in the world of Ortho, you need to follow this. Ok, here we go!
CMS has long included the use of various clinical measures, which have included Patient-Reported Outcome Measures (PROMs) and Patient Reported Experience Measures (PREMs). PROMs have been included as part of the MIPS and MACRA programs in the past. PROMs will continue to be a valid and important measure in the dQMs RFI process. In the May 10, Federal Registry, CMS has placed a hold on PREMs for the 2022 Calendar year, due to the COVID-19 Public Health Emergency. PREMs will play a role in future measures, however, next year will be given a reprieve due to statistically significant, and across the board, changes to hospital PREMs scores proposed related to COVID-19. PREMs will return in 2023 when the public health emergency is scheduled to end.!
“In this section we seek to refine the definition of Digital Quality Measures (dQMs) to further operationalize our objective of fully transitioning to dQMs by 2025. We previously noted dQMs use ‘‘sources of health information that are captured and can be transmitted electronically and via interoperable systems.’’ (85 FR 84845) In this RFI, we seek input on future elaboration that would define a dQM as a software that processes digital data to produce a measure score(s). Data sources for dQMs may include administrative systems, electronically submitted clinical assessment data, case management systems, EHRs, instruments (eg. medical devices and wearable devices), patient portals or applications (eg. for collection of patient-generated health data), Health Information Exchanges (HIEs) or registries and other sources. We also note that dQMs are intended to improve the patient experience including quality of care, improve the health of populations, and/or reduce costs.” (Federal Register, page 25550)
Clinical Measures aren’t new for CMS, but the emphasis on PROMs and PREMs is going back up.
CMS has long included the use of various clinical measures, which have included Patient-Reported Outcome Measures (PROMs) and Patient Reported Experience Measures (PREMs). PROMs have been included as part of the MIPS and MACRA programs in the past. PROMs will continue to be a valid and important measure in the dQMs RFI process. In the May 10, Federal Registry, CMS has placed a hold on PREMs for the 2022 Calendar year, due to the COVID-19 Public Health Emergency. PREMs will play a role in future measures, however, next year will be given a reprieve due to statistically significant, and across the board, changes to hospital PREMs scores proposed related to COVID-19. PREMs will return in 2023 when the public health emergency is scheduled to end.
The value of PROMs and PREMs is not in question. CMS understands the value and wants to collect the data more quickly and easily. The challenge is what survey tools to use and how to collect electronically the data necessary to make value-based reimbursement decisions.
While the RFI has identified CMS interest in this collection and value of data, unfortunately, there are a few issues that must be addressed. Electronic collection through various sources has yet to be proven to collect a reliable and statistically significant percentage of patient data. Electronic Health Records (EHR) currently hold some value in that they often include valid PROMs, such as the HOOS (hip) and KOOS (knee), yet EHRs do not guarantee consistent, appropriate and timely gathering of information.
It will be challenging for EHRs, but AAOS has some great recommendations.
A challenge for EHRs will be bolting additional software onto their systems. This will create additional costs for providers as the EHR companies pass the cost onto users. These companies will also have to pay proprietary costs for PROMs since becoming part of a commercial product. All these additional costs will increase providers expenses while not providing additional revenue. The EHR companies will also not be collecting the data or surveys. That will remain the administrative duty of the providers. Further increasing cost and demands on providers.
The American Academy of Orthopedic Surgeons (AAOS) has requested that common, current patient-reported outcomes (PROs), such as HOOS and KOOS, be used since they are already reliable and valid.
These surveys have also been used for years, setting precedence and allowing for benchmarking and analysis.
AAOS has recommended that using registries provides for collection and reporting of these surveys. Permitting the registries to report this data helps reduce a redundancy of data collection, while also removing some of the cost and demand from providers.
More good news: There are already companies that exist for this very purpose.
Companies, such as CODE Technology, already collect these data points for thousands of providers. Permitting a company like CODE to report to CMS, rather than shifting to EHRs, saves provider cost and time. This policy also allows the people currently collecting the data to continue and maintain collecting, analyzing and reporting data. CMS has recognized the value and importance of PROMs and PREMs. An RFI permits people and organizations to respond about their concerns and provide information to CMS.
CODE Technology supports this RFI and requests that electronic collection of PROs continue. However, CODE would not support only EHRs providing this data to CMS. CODE asks that CMS continue to explore options of private companies, registries and providers themselves the ability to collect, analyze and report various PROMs and PREMs.
See The 10 Step Guide to Spearheading an Outcomes Program
If you are interested in reporting your PROMs to CMS and want to know more about how to get started, check out our 10 Step Guide to Spearheading an Outcomes Program to start planning your PRO program today!