Last Fall, the MACRA Final Rule was released and the AGA published an article listing the MACRA quality measures that affect all gastroenterologists who care for Medicare patients.
This article revealed 8 health maintenance/chronic care measures (i.e. smoking cessation, unhealthy alcohol use) and 8 GI-specific quality measures: 2 on IBD, 2 on Hepatitis C, and 4 on colonoscopy. Of these 8 quality measures, 1 Hepatitis C measure (#390) is classified as a “high priority measure” by CMS and all 4 colonoscopy measures are considered “high priority.”
Of the dozen or more colonoscopy quality measures considered, the four “high priority” colonoscopy measures listed on the CMS Quality Payment Program (QPP) website include:
#185 — Colonoscopy Interval for Patients with a History of Adenomatous Polyps – Avoidance of Inappropriate Use
#320 — Appropriate Follow-Up Interval for Normal Colonoscopy in Average Risk Patients
#343 — Screening Colonoscopy Adenoma Detection Rate Measure
#439 — Age Appropriate Screening Colonoscopy
Tracking just four colonoscopy measures sounds easy!
The devil is in the details
Let’s break down the nitty-gritty of the requirements, data collection and submission process. For more details, please see my powerpoint presentation.
You are exempt if you:
Collect less than $30,000 in Medicare/yr.
See fewer than 100 Medicare part B patients
Are in your first year of enrollment in Medicare
Participate in APM (Alternative Payment Model)
To maintain neutrality and avoid a 3% hole (from which you must climb in subsequent years), report just one measure beginning no later than October 2017. This single measure may come from any of the 3 categories:
If you report using a Certified EHR, you’re set for 2017!
After 2017, you must report 6 Quality Measures, 5 Advancing Care Measures, and 4 Improvement Activities to remain neutral. If your performance is exceptional, you will receive a bonus.
To assure that 4 out of the 6 required colonoscopy quality measures are reported:
Know and comply with screening/surveilance guidelines
Collect and compile required data:
Primary indication (dependent on family history and personal history of colorectal cancer or polyps – including their number, size and pathology)
Date of last colonoscopy, its prep quality and extent
Pathology of current polyps
To get the remaining 2 quality measures, 5 Advancing Care Measures, read on!
There are several data submission methods relevant to colonoscopists: through claims, Qualified Registries (QRs), Qualified Clinical Data Registries (QCDRs), EHR, and the CMS web interface. Claims submission is only allowed for individual submission and the CMS web interface is only available for large groups of 25+ providers.
A closer look reveals that only quality #185 can be submitted via claims or registry, whereas #320, #343, and #439 can only be submitted through a registry. This means that you must submit data through a registry in order to meet the 4 colonoscopy metrics.
Unless you are part of a large 25+ physician group, you are likely reporting as an individual or small group and are required to use a registry.
What is a “registry?”
Registries are very simple: they collect specific population data and map their data fields to specific MIPS (PQRS) quality measures and send that mapped data to Medicare on your behalf in XML format. The main advantage of a QCDR is that it collects all 6 of the required colonoscopy quality measures credits you with an Improvement Category. If you use the right QCDR and a fully functional and certified EHR, all of your MACRA/MIPS requirements can be met (make sure these are all activated!)
What registry should I use?
First, check to see if your EHR vendor is currently certified. Some may also have certification as a QCDR for colonoscopy. The latter may be the easiest submission method.
Otherwise, I recommend that you use GIQuIC (GI Quality Improvement Consortium, Ltd.) as your QCDR, created as a non-profit collaboration of the American College of Gastroenterology (ACG) and the American Society for Gastrointestinal Endoscopy (ASGE). GIQuIC costs between $500 to $800 per provider per year.
GIQuIC has over 100 input fields for colonoscopy and over 80 for EGD. Additional population health quality measures are calculated by GIQuIC automatically.
Most endowriters, including Qualoscopy, have data mapping capabilities with GIQuIC. Familiarize yourself with these data fields and make sure you include them in every colonoscopy report you create (and avoid free-texting)! Qualoscopy assures that these data are correctly entered and provides one-button submission to GIQuIC.
MACRA is here to stay. Failure to participate will eventually reduce your Medicare reimbursements by 9%. Active involvement in MACRA can maintain neutral reimbursement, and for those who rigorously report all categories as top performers, bonus above neutrality could reach 9% in 2022. That’s an 18% swing! The costs to fully participate in MIPS/MACRA include purchase of a Certified EHR, a MIPs-ready endowriter that can report to a QCDR (e.g., GIQuIC), back-office staff to update data and polyp pathology, and a yearly registry subscription. For some, these expenses will dissuade participation.
Qualoscopy understands these potential rewards and costs and has developed solutions that maximize reimbursement, quality care and quality of your life!