On January 1, 2017, CMS began a new method for determining Medicare payments to Qualified Health Professionals (QHPs) like physicians and nurse practitioners. Most QHPs are subject to the Merit Based Incentive Payment System (MIPS) which requires, among other things, the reporting of quality data. Data are usually reported to CMS through Qualified Clinical Data Registries (QCDRs).

CMS has approved the US Wound Registry (USWR) as a MIPS registry. A complete list of the USWR wound care measures can be found on the USWR website.

Participation impacts reimbursement. For example, Qualified Health Professionals who do not participate in MIPS in 2017 will lose 4% of their Medicare Part B revenue. However, it is also possible for practitioners to earn substantial bonus payments under MIPS. The wound care quality measures available through the USWR allow clinicians who practice wound care and hyperbaric medicine to demonstrate their commitment to the highest possible quality practice standards.  

Data indicate that practitioners reporting USWR quality measures are more likely to appropriately treat diabetic foot ulcers and venous leg ulcers than practitioners who do not reporting USWR quality measures.

Quality Measure Reporting: “Do the Right Thing”

The USWR conceived a program called "Do the Right Thing" to raise the standard of care for patients with chronic wounds. As one example, the quality measure for adequate compression of venous ulcers at each visit can be passed with any system that can provide at least 30 mmHg at the ankle (e.g. multilayer bandages, Unna's boot, 30 mmHg stockings, etc.). In 2016 (5 years after the original study demonstrating that compression was applied adequately in only 17% of visits), the average performance rate among those who reported the venous compression measure to CMS was 80.4%, compared to 26% for those who did not report the measure to CMS.

Among practitioners reporting the arterial screening measure, the average performance rate was 69%, whereas among those who did not report the arterial screening measure, the performance rate was 25.7%.

The Good News

  • The data from the USWR demonstrate how quality reporting can raise the bar on the standard of care for patients with wounds.
  • The USWR set benchmark rates for many wound care processes.
  • Some wound care practitioners will get bonus money as a result of engaging in MIPS through the USWR.
  • USWR measures will be available as SMART Apps for use inside Epic on January 1, 2018.
  • It is hoped that the ability to install wound care quality measures in this manner will overcome some of the barriers to quality reporting.



The Bad News

  • Loss of important measures: CMS rejected the patient reported Wound Quality of Life as a Quality Measure in 2017. Although 400 patients took the wQoL and detailed wound data were collected for a validation study, developers of the w-QoL were unable to secure funding to perform the validation study. CMS rejected the quality of life measure because it was not possible to establish a benchmark for a specific percentage increase in QOL in response to wound care. It is unfortunate that CMS chose not to support this measure, and manufacturers chose not to fund the validation study.
  • Lack of support for needed measure development. Outcome measures are needed for wounds treated with cellular products and negative pressure since reimbursement of these advanced therapeutics will be jeopardized if it is not possible to tie cost to improved outcomes under MIPS. However, there is no support for additional measure development and thus far, little interest in measure reporting by wound care practitioners.

Why Report?

QHPs who participate fully in MIPS can earn a substantial bonus payment (12% of Medicare part B payments, and possibly more). Wound care practitioners might also note that “Yelp,” a popular internet search and review service, has entered into an agreement with “Physician Compare” which will incorporate physician quality reporting data into the Yelp star ratings for physicians.

Clinicians who participate in quality reporting have raised the bar on their clinical practice. As just one example, among the clinicians who reported the arterial screening quality measure, the average performance rate was a respectable 69%. In contrast, the average performance rate of arterial screening among the physicians who did NOT report this measure was a disappointing 25.7%. That’s why the USWR calls its quality reporting initiative “Do the Right ThingTM”.

The USWR sponsors many Clinical Practice Improvement Activities (IAs) directed at, for example, improving a clinician’s performance rate of vascular screening, nutritional screening, venous compression or diabetic foot ulcer off-loading. The USWR calls its IA projects “Care that Counts.” In 2017, clinicians can keep all of their Medicare Part B payments by simply participating in one IA. This is a vendor neutral program. It doesn't matter what EHR you use.



The Future of Reporting

The USWR QCDR measures are available as electronic Clinical Quality Measures (eCQMs) that can be installed into any certified EHR, although this process is not simple and EHR vendors charge money for it. EHR vendors are currently preparing for the next stage of EHR certification (“2015 Certification”) the deadline for which is actually January 1, 2018. EHR vendors will be required to support interfaces that utilize FHIR® (Fast Healthcare Interoperability Resources) as part of the “open Application Programming Initiative (API).” This means that in 2018, EHRs will be able to support quality measures as “apps.” The USWR QCDR quality measures will be available as apps, so if your EHR vendor has previously blocked your participation in the USWR, that situation should change in 2018. More importantly, new legislation has been passed which will hold EHR vendors accountable for “data blocking” such as refusing to transmit Continuity of Care documents for registry participation.

References

  1. Centers for Medicare and Medicaid Services. Quality Payment Program. https://qpp.cms.gov/.Accessed August 8, 2017.
  2. Centers for Medicare and Medicaid Services. Pay-for-Performance/Quality Incentives. May 24, 2005. https://www.cms.gov/Regulations-and-Guidance/Guidance/FACA/downloads/tab_H.pdf. Accessed August 8, 2017.
  3. U.S. Wound Registry (USWR). USWR Sets the Pace for Providers to Thrive Under CMS’ Quality Payment Programs. USWR Approved by CMS as MIPS 2017 QCDR. June 6, 2017. http://uspodiatryregistry.com/Files/Approved/USWR_6-6-2017.pdf. AccessedAugust 8, 2017.
  4. Centers for Medicare and Medicaid Services. Quality Payment Program. MIPS Overview. https://qpp.cms.gov/mips/overview. Accessed August 8, 2017.
  5. Centers for Medicare and Medicaid Services. The Merit-Based Incentive Payment System: MIPS Scoring Overview. https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/MIPS-Scoring-Methodology-slide-deck.pdf. Accessed August 8, 2017.
  6. Fife CE, Horn SD, Smout RJ, Barrett RS, Thomson B. A predictive model for diabetic foot ulcer outcome: the Wound Healing Index. Adv Wound Care (New Rochelle). 2016; 5:279-287.
  7. Centers for Medicare and Medicaid Services. Stage 3 Program Requirements for Providers Attesting to their State’s Medicaid EHR Incentive Program. https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Stage3Medicaid_Require.html. Accessed August 8, 2017.
  8. HL7.org. 2.11 Fast Healthcare Interoperability Resources (FHIR) Overview. https://www.hl7.org/fhir/overview.html. Accessed August 8, 2017. 
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