To avoid these penalties in 2018, a specialty care provider (either individually or as part of a group practice) will need to submit data on his or her 2016 performance during the first quarter of 2017. Specifically, a physician must report on at least nine measures selected from a list of more than 270 PQRS-approved measures. The nine selected measures must cover at least three of the six National Quality Forum domains (patient safety; person and caregiver-centered experience and outcomes; communication and care coordination; effective clinical care; community/population health; and efficiency and cost reduction). Also, at least one of the reported measures must appear on CMS’ list of 23 “cross-cutting” measures unless the physician has no face-to-face encounter with a Medicare beneficiary during the performance year.
For each PQRS-approved measure, CMS provides specifications on how a physician or group practice should compile and report data. Failure to meet these specifications for any reported measure will result in rejection of the physician’s or group’s submission.
To assist physicians in identifying appropriate measures on which to report, CMS has developed 17 preferred specialty measure sets, including one for oncology/hematology. An oncologist is not required to report on the eight measures included in the set; CMS has compiled the specialty sets for purposes of guidance only:
Beginning next year, both PQRS and the VM Program will be replaced by the Merit-Based Incentive Payment System (MIPS), with its own set of quality measures and reporting requirements. Like PQRS, the MIPS proposed rule includes a list of several hundred quality measures from which a physician may select. Unlike PQRS, a physician will be required to report on only six measures, including one cross-cutting and one outcome-based measure.
In a previous article, we detailed the significant impact MIPS will have on all physicians, including specialty care providers. Thus, it is critically important that specialty care providers begin work now on performance improvement initiatives to maximize their MIPS scores. As a first step, practices should identify specific quality measures and implement processes to ensure qualifying patients receive the prescribed evaluation or treatment.
The MIPS proposed rule includes 23 specialty-specific measure sets, but CMS did not include a measure set for oncology. As oncologists prepare to master MIPS, there are three sources of relevant measures:
1. Six of the eight measures included in the 2016 PQRS specialty measure set for hematology/ oncology are included on the proposed list of MIPS quality measures. The two excluded measures are (1) Breast Cancer: Hormonal Therapy for Stage IC-IIIC Estrogen Receptor/Progesterone Receptor (ER/PR) Positive Breast Cancer and (2) Colon Cancer: Chemotherapy for AJCC Stage III Colon Cancer Patients.
2. CMS published seven core measure sets earlier this year. Developed by the Core Quality Measures Collaborative (CQMC), the measure sets include a fourteen-measure set for medical oncology. The CQMC utilized a multi-stakeholder approach to identify measure sets that are meaningful to patients, payers, and providers. Initially focusing on breast, colorectal, and prostate cancer, as well as hospice and end-of-life care, the measures concentrate predominantly on processes and treatment utilization.
All but two of the fourteen measures are included on the proposed list of MIPS quality measures:
The CQMC indicated its work in medical oncology is ongoing, and the group intends to develop additional core measures addressing the following:
- Pain control
- Functional status or quality of life
- Shared decision-making
- Appropriate use of chemotherapy
- Under or overtreatment
- ER utilization
- Inpatient hospital admission rate
- Reporting of cancer stage
- Disease- free survival for specified number of years
- Patient experience/PRO for level of pain experience by patient
- Cost measures
- Lung cancer
- Five year cure rate
3. CMS announced the 196 oncology practices to participate in the Oncology Care Model late last month. As part of the formal Participation Agreement these practices were required to sign, CMS identified the 16 required quality measures. Nine of the 16 measures are included on the proposed list of MIPS quality measures:
Interestingly, only one measure appears on all four lists – the 2016 PQRS hematology/oncology specialist list, the CQMC Core Measures for medical oncology, OCM measures, and the proposed list of MIPS quality measures:
Oncology: Medical and Radiation: Pain Intensity Quantified (NQF 0384/PQRS 143)
Percentage of patient visits, regardless of patient age, with a diagnosis of cancer currently receiving chemotherapy or radiation therapy in which pain intensity is quantified
With this background on options for quality reporting, we will discuss strategies for proper measures selection, including performance improvement initiatives, in a future article.