ACO Members Facing 2017 Penalties Can Submit PQRS eCQM Data

By Stacy Tyman, Director of Strategic Accounts, Health eFilings, LLC

On November 4th, 2016, CMS issued a final rule on changes to the Medicare Shared Savings Program requirements. As part of these changes, CMS acknowledged that there were some ACOs who did not successfully report Quality Measures Data for their members in 2015. As such, members of these ACOs will be penalized beginning January 1st, 2017. As one can imagine, this information was both concerning and shocking to ACO members who had joined ACOs with the understanding that the ACO would handle all the required reporting.

While simultaneously acknowledging that it is the responsibility of the ACO to let their members know if they are not able to report for them, and the ACO member to find an alternative reporting method, CMS also acknowledged that this is not always the case. To alleviate the financial burden on ACO members who may not have been informed, or had the time to seek alternative reporting methods, CMS has offered the chance at a secondary reporting option.

According to CMS: “to allow affected EPs that participate in an ACO to report separately for the CY 2017 PQRS payment adjustment, we proposed a secondary PQRS reporting period for EPs that were in an ACO that did not successfully report quality data on behalf of the EPs in the group and those who are solo practitioners.”

In other words, for those participating in a Shared Savings Program ACO that received notification from that CMS they will be penalized, the ACO member for PQRS and the Value Based Payment Modifier starting in January of 2017, the ACO member has an opportunity to submit PQRS Quality Measures Data during the 2016 submission period (January 1, 2017-February 27, 2016) to avoid impending penalties. These penalties could cost members thousands, if not hundreds of thousands of dollars. ACO member PQRS eCQM data submitted for the 2016 Reporting year will count towards both their 2015 requirements and act as a secondary submission for 2016 should their 2016 ACO submission not be accepted. This will impact both future reimbursements for CY2018, and retroactively impacting reimbursements for CY2017. It is important to note that that the ACO cannot directly support members in taking advantage of this opportunity. CMS explicitly states that the effected EP or group must “separately report outside the ACO.” Additionally, reported measures must be PQRS eCQMs and not ACO measures. It is therefore incumbent upon the member to determine how to comply and submit the required data.

As the 2016 submission period opens, the burden on ACO members being penalized is significant – but it doesn’t have to be. Saving time and money on this arduous reporting process means finding the right partner. While CMS has provided options to comply with these programs, not all reporting methods are equal. Submitting through a registry means a lengthy manual process to pull data, complete chart abstractions, and select measures. Data Submission Vendors (DSVs) on the other hand, afford the option of an automatic software based solution, in place of a manual process, removing the administrative burden for the ACO members.

The challenge ACO members facing 2017 penalties have is not only helping to recoup costs from penalties attached to their 2015 submission, but also simultaneously working to protect their 2016 submission. Selecting a DSV to simplify and automate this process will be critical. ACO members must act quickly – all required data must be submitted by the close of the 2016 submission window on February 27, 2017. The time is now to choose a DSV who can help ensure you’re on the right track to avoid penalties in 2017 and beyond.