Maintenance of Certification Reporting Option
Section 3002(c) of the ACA requires a mechanism under which a physician may provide data on quality measures through a Maintenance of Certification Program (MOCP) operated by a specialty body of the American Board of Medical Specialties (ABMS), with an additional 0.5 percent incentive payment for years 2011 through 2014 if certain requirements are met. These requirements include that the physician must satisfactorily submit data on quality measures under the PQRI for a year and have such data submitted on their behalf through the MOCP. Physicians must also more frequently than is required to qualify for or maintain Board certification status, participate in an MOCP for a year, and successfully complete a qualified MOCP for a year.
CMS must provide further clarification on the requisite interconnected steps and processes for participating in the PQRI and MOCP to qualify for the additional 0.5 percent incentive. Without clearer articulation, physicians will not be able to understand the necessary processes to qualify under what is already a detailed and at times overwhelming incentive program. Further, requiring physicians to interact with both CMS carriers and the Medical Boards on an added PQRI reporting option allows for confusion and duplication of effort. If this additional reporting option is to succeed, CMS and the Boards must work together prior to January 1, 2011, to clarify the parameters and processes of this added reporting option, and communicate PQRI MOCP reporting option requirements clearly and often to physicians.
Further, to engage in an MOCP “more frequently” in the current health care environment, comprised of new requirements and programs, e.g., RUR meaningful use, will severely deter or even prevent many physicians from electing the MOCP option in 2011. The AMA understands that most Boards do not have a fully developed and tested Part IV MOCP, which is referred to as “practice assessment.” Therefore, if most Boards do not have operational and tested “practice assessment” capability, it is not possible for physicians participate in the program at all, much less “more frequently.” We look forward to working with CMS and the Boards to improve the availability of operational and tested practice assessment programs, such as condition-specific Practice Improvement Modules (PIMs). These modules incorporate quality measures that permit physicians to complete the module using their own patient population to produce a quality improvement score.
Physicians will further have difficulty meeting the “more frequent” standard because, as we understand, some practice assessment activity must be competed every one to four years. “More frequent” compliance could occur every two years, for example, and therefore, would not align with current PQRI reporting periods. In addition, meeting the “more frequent” standard in these instances may not yield meaningful learning from the collection and reporting of quality measures because evidence-based medicine, although a dynamic process, may not have substantially changed.
Even if a physician has the ability to participate in a practice assessment on a “more frequent” basis, issues of accurate data capture and transmission to CMS remain questionable. If practice assessment data for a physician were submitted through an MOCP that meets the criteria for a registry under the PQRI, the only PQRI qualified Board registry currently available, according to the 2010 PQRI Qualified Registries, would be the American Board of Family Medicine. Since no other Board registries exist under the PQRI, it is questionable whether they would have the capability to submit data for the 2011 PQRI (and beyond). While more Boards may request to qualify as a registry in 2011 or satisfy the rule by “meeting the criteria for a registry,” as noted in the proposal, most Boards will not be able to do so, preventing most physician specialties from electing to participate in the PQRI MOCP reporting option.
Additionally, the AMA believes there is inadequate time to test whether MOCPs have the capabilities to collect and transmit quality data to CMS accurately and consistently. Testing must occur first. If MOCP or CMS systems are faulty, CMS must provide a formal opportunity for physicians to file a complaint.
To qualify for the additional incentive payment, the MOCP should submit to CMS in a form or manner specified by the Secretary, that the physician has successfully completed a qualified MOCP practice assessment for such year, as well as the methods, measures, and data used under the MOCP and qualified MOCP practice assessment. Only “if requested by the Secretary,” does information on the survey of patient experience need to be provided. The AMA urges patient experience information not be submitted, as the collection methods and data accuracy associated with patient experience lack uniformity and validity.
Under the ACA, the Secretary has the discretion to incorporate participation in an MOCP and successful completion of a qualified MOCP practice assessment into quality composite measures for purposes of the physician fee schedule payment modifier under section 3007 of the ACA. Considering incorporation of MOCP as part of the physician fee schedule payment modifier is premature. The Secretary should not adopt this approach until there is ample time to understand and act upon lessons learned with the PQRI MOC reporting option.
In addition to requiring Boards to either operate a qualified PQRI registry or to self-nominate to submit MOCP data to CMS on behalf of their members, CMS is also considering requiring the various Boards to submit data to ABMS and ABMS would then channel this information from the Boards to CMS. The AMA understands that the medical Boards and their representative organizations do not have the tools or resources to facilitate this type of data transfer. While this may be a temporary option for handling the data transfer from smaller Boards, it is an inefficient, piecemeal approach which places unnecessary data transfer burden and additional costs on the larger Boards that have not yet proven they can manage submission directly to CMS. The AMA remains concerned about the integrity of physician quality data, and it is critical that CMS not focus on data transfer for the sake of data transfer, but on adopting structured and understandable objectives for transferring and interpreting health care quality data.