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    Physician Performance Measure Development


    Position Papers

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    A Nephrologist’s Guide to National Initiatives

    Performance Measurement, the systematic collection of outcome, process, structural, access, or patient experience indicator of data over time, has a growing impact on the practice of nephrology. In the past, clinical performance measures (CPMs)* have been used predominantly for quality assurance, quality improvement, and public accountability. Increasingly, however, private and public payers are using CPMs as preconditions for of determinants of payment, including pay for reporting and pay for performance. In addition, payers are also instituting nonpayment for specific complications experienced by patients or reduced payments for non-participation in programs such as e-Prescribing.

    To provide a greater understanding of performance measurement activities affecting nephrology practitioners, RPA has created and maintains this portal to assist you in navigating how multiple performance measurement efforts interrelate and how you can comply with the various requirements in real time. The following information has been compiled for easy access and reference:

    • What are the measures that apply to the kidney patient population?
    • Why are the measures important?
    • Where are the measures housed and maintained/updated?
    • What do nephrology practitioners need to know to utilize the measures?

    Additionally, in early 2010 RPA developed a position paper entitled RPA Guidance on Development and Application of CPGs and CPMs in Nephrology Practice. This document provides detailed information regarding the history of performance improvement efforts in the U.S., the key organizational players in this arena, the roles of these key players in system-wide quality improvement endeavors, and how variability of understanding key concepts can affect performance improvement efforts.

    * A Clinical performance measure (CPM) is a mechanism for assessing the degree to which a provider competently and safely delivers clinical services that are appropriate for the patient in the optimal time period. In other words, CPMs estimate or monitor the extent to which the actions of a health care practitioner or provider conform to practice guidelines, medical review criteria, or standards of quality.

    Outcome and process measures are usually calculated in rates (e.g., numerator of people with the outcome or who received the process of care divided by a denominator of people who were eligible for achieving the outcome or receiving the process of care times 100).

     

    Instructions for Use

    Performance measurement activities fall into the following main categories: measure development, measure endorsement and adoption, and measure implementation. Each component will include a description of the activity, its status, RPA’s role in its development or implementation, and guidance on how to comply. In order to ensure this document remains up to date, much of this information is provided with links to the source materials.

     

    PERFORMANCE MEASUREMENT ACTIVITIES AFFECTING NEPHROLOGY PRACTITIONERS

     

    Measure Development

      
    A measure is developed through a defined process by an organization such as the Centers for Medicare and Medicaid Services (CMS), Agency for Healthcare Research and Quality (AHRQ), American Medical Association (AMA)-convened Physician Consortium for Performance Improvement (PCPI), RPA, and others. The RPA endorses the requirements for practice guidelines and performance measures set forth by the AHRQ. Measures may be directed at the physician-level or facility-level.
       
    Project Name  ESRD Clinical Performance Measures (CPM) Project  
    Description 
    Balanced Budget Act (BBA) required CMS to develop and implement a method to measure and report the quality of renal dialysis services provided under the Medicare program. To implement this legislation, Centers for Medicare and Medicaid Services (CMS) funded the development of CPMs based on KDOQI guidelines.  These are being rolled out in phases.
    Status

    April 2008 – CMS Phase III developed 26 new facility level CPMs in order to further monitor the quality of care being delivered to ESRD patients.

    March 2010, Phase IV – contracted with Arbor Research Collaborative For Health (Arbor Research) and University of Michigan Kidney Epidemiology and Cost Center (UM-KECC) to develop Quality Measures for ESRD for Anemia Management/Iron Targets,  Mineral and Bone Disorder, Hemodialysis Vascular Access Related Infections, Pediatric Hemodialysis Adequacy,Pediatric Anemia, and Fluid Weight Management. As part of the measure development process, Technical Expert Panels (TEPs) were formed to provide expertise and input. TEPs also defined target values for existing ESRD measures. These measures were submitted to National Quality Forum (NQF) in Sept 2010. 
    RPA's Role

    Little involvement on an organizational level. A few RPA members were involved in the Clinical Technical Expert Panels. 

    Resources Available/ Participation Information 
    2008 CPMs 
    Status of CMS measures submitted to NQF in Sept 2010  
       
    Project Name
    AMA Physician Consortium for Performance Improvement (PCPI)  
    Description
    Develops evidence-based, specialty-specific, physician-developed quality measures
    Status
    The Kidney Disease Workgroup developed 6 ESRD (adult) measures, 6 CKD measures, and 2 ESRD (pediatric) measures.  Adult ESRD and CKD measures were pilot tested in four nephrology practices. Testing was completed and the report was generated in February 2009. 

    The adult ESRD measures received a time-limited endorsement from NQF. The pediatric measures were not endorsed by NQF. As of December 2010, the CKD measures had not been submitted to NQF because there had not been a “call for CKD measures”.

    The workgroup was reconvened Oct 2010 to review/revise the existing CKD and ESRD measures and consider development of new measures based on RPA’s shared decision-making clinical practice guideline that was published in October 2010. These measures were submitted to NQF in June 2011 in response to a “call for renal measures”.
    RPA's Role
    RPA serves as the lead organization for the Kidney Disease Workgroup.

    RPA is a voting member of AMA PCPI and frequently consults with content experts.

    Resources Available/ Participation Information
    Adult ESRD Measures
    CKD Measures 
    Pediatric ESRD Measures 
       
    Project Name
    Kidney Care Partners      
    Description Kidney Care Partners is a coalition of patient advocates, dialysis professionals, care providers and manufacturers working together to improve quality of care for individuals with Chronic Kidney Disease.
    Status KCP Measures workgroup is currently examining the measures CMS has submitted to NQF and will make recommendations to the KCP Board about whether KCP should support a measure as currently specified, support with modifications, or oppose.
    RPA's Role
    RPA content experts participate in KCP including the measures workgroup. 
    Resources Available/ Participation Information
    KCP Overview 
    List of measures for 2010 KCP review   


    Measure Review - Endorsement and Adoption


    Review, revision and endorsement of measures based on evidence.  This process that usually entails field testing of the measures prior to consideration for endorsement. RPA recognizes Ambulatory care Quality Alliance (AQA) and National Quality Forum (NQF) as the designated entities who endorse measures.
    Project Name
    National Quality Forum (NQF) 
    Description Reviews, revises and endorses proposed measures developed by others.  Serves as CMS’ preferred measure endorsement entity for public value based purchasing programs.
    Status
    Ongoing – maintains a clearinghouse of measures that have been endorsed. AMA-PCPI and RPA will submit the adult ESRD measures for maintenance in Jan 2011; additionally, new CKD and palliative care measures will be submitted at that time.
    RPA's Role
    RPA was granted membership in NQF 12/2005.  RPA is a voting member.

    RPA submitted 4 nominees to serve on the ESRD Steering Committee; 3 were appointed in 2010.
    RPA, in conjunction with AMA PCPI, submitted 8 measures during the NQF's call for renal measures in June 2011. It is expected that these measures will be reviewed by the NQF CSAC on Aug 16-17, 2011.

    Resources Available/ Participation Information 
    List of NQF-endorsed measures 


    Measure Implementation

    Use of, facilitation of use, of measures and subsequent reporting on/grading of measure use.


    Project Name
    Physicians Quality Reporting System (PQRS) (Formerly PQRI) 
    Description
    Use of claims-based, measures groups or registry reporting to  report process quality measures for Medicare beneficiaries who met the measure criteria, for incentive bonus payments.
    Status
    Voluntary CMS Program in place as of 7/1/07.  Includes  CKD,  ESRD, and pediatric ESRD quality measures.  Updated annually and published in the Medicare Fee Schedule. 2012 PQRS measures and incentives are included in the final Medicare Fee Schedule.
    RPA's Role
    All CKD & ESRD measures in program were developed by RPA/PCPI.
    Incentives or Adjustements
    Eligible professionals can earn a 0.5% incentive payment in 2012.
    Resources Available/ Participation Information How to Participate (CMS Guide)
    List of all PQRS Measures   
    RPA guide to participating, including reporting options and relevant measures 


    Project Name
    Electronic Prescribing (eRx) Incentive Program 
    Description
    The transmission, using electronic media, of prescription or prescription-related information between a prescriber, dispenser, pharmacy benefit manager, or health plan either directly or through an intermediary, including an eRx network.

    A successful individual eRx prescriber must generate and report one or more eRxs associated with a patient visit, a minimum of 25 unique visits per year. Each visit must be accompanied by the eRx G-code attesting that during the patient visit at least one prescription was electronically prescribed.
    In order to report this measure, a qualified electronic prescribing (eRx) system must have been adopted.
    Status
    CMS program started in 2009. The eRx program is separate from and is in addition to the Physicians Quality Reporting System (PQRS) [Formerly PQRI]. Eligible professionals do not need to participate in PQRI to participate in the Electronic Prescribing (eRx) Incentive Program.
     
    In November 2010, CMS announced that beginning in 2012, eligible professionals who are not successful electronic prescribers may be subject to a payment adjustment.
    RPA's Role 
    RPA submitted comments to CMS on the final rule in Dec 2008 on issues such as the eligibility requirements for eligible professionals and the measure denominators.
    Incentives or Adjustments
    Eligible professionals can earn a 1% incentive payment in 2012. 

    Notes:
    Earning an EHR incentive in 2011 does not exempt an eligible professional from the payment adjustment.
    Incentive not available to professionals receiving 2011 incentive from Medicare EHR Incentive Program (Meaningful Use program).

    Resources Available/ Participation Information
    Overview of the eRx program  
    How to Get Started (CMS Guide)  
    Explanation of 2012 Payment Reductions  
    2012 eRx Measure Description 



    Project Name
    Ambulatory care Quality Alliance (AQA)  
    Description
    American Academy of Family Physicians (AAFP), the American College of Physicians (ACP), America’s Health Insurance Plans (AHIP), and the Agency for Healthcare Research and Quality (AHRQ), formed the Ambulatory care Quality Alliance to facilitate timely implementation of physician-level measures.
    Status
    Approved by CMS in 2007 and 2008 to adopt quality measures for inclusion in the Medicare PQRI program. 
    RPA's Role
    RPA is a voting member of the AQA.
    Incentives or Adjustments N/A
    Resources Available/ Participation Information List of AQA-approved measures 
    AQA Parameters for Selecting Measures for Physician and Other Clinical Performance  


    Project Name
    Medicare and Medicaid EHR Incentive Program - "Meaningful Use" 
    Description

    Established by the American Recovery and Reinvestment Act (ARRA) of 2009, to acknowledge the necessity of implementing widespread use of electronic health records (EHRs) and the fact that doing so would be prohibitively expensive for most medical practices. To address the necessity and cost-prohibitive concerns regarding EHR implementation, ARRA made a $19 billion investment intended to assist physicians and hospitals in purchasing EHR systems.
     
    Under the Medicare incentive program, each eligible professional (non-hospital based) may qualify for up to $44,000 in Medicare incentives over a five-year period beginning in 2011. Eligible professionals (EPs) who furnish more than 50 % of covered services in a geographic Health Professional Shortage Area (HPSA) are eligible for an additional 10 % incentive on top of the maximum incentive payment amount.

    Status
    On July 13, 2010 CMS released the final regulation on the Medicare and Medicaid EHR incentive program. This final rule pertains to Stage 1, which covers the first two years of adoption and meaningful use of certified EHR technology. Stages 2 and 3 will be defined in future rulemaking.

    The program began Jan 1, 2011. Eligible Professionals must complete 15 core objectives; 5 objectives out of 10 from menu set; and 6 total Clinical Quality Measures (3 core or alternate core, and 3 out of 38 from additional set).

    RPA's Role
    RPA submitted comments to CMS on the proposed rule on issues such as insurance eligibility and claims requirements, computerized provider order entry (CPOE), clinical quality measures, patient-system interaction, privacy and security audit requirements, and laboratory results management. Some of these issues were addressed in the final rule.
    Incentives or Adjustments Eligible professionals can earn up to $44,000 in incentives for successfully participating in the Medicare program OR $63,750 for the Medicaid program.
     
    Note:
    Eligible professionals cannot receive incentive payments for both Meaningful Use and e-prescribing program.
    Resources Available/ Participation Information Getting Started with Meaningful Use (CMS Guide)  
    Meaningful Use Program Overview    



    Project Name
    Physician Compare Web Site 
    Description
    Required by Section 10331 of the Affordable Care Act, the Physician Compare Web site will contain information on physicians enrolled in Medicare and other eligible professionals who participate in Physicians Quality Reporting System (PQRS) [formerly PQRI] and e-prescribing (eRx).
    Status
    CMS is required to establish the site by January 1, 2011. Section 10331 of the Affordable Care Act also requires CMS to implement a plan to make information on physician performance publicly available through the Physician Compare Web site no later than January 1, 2013.  It is expected it would include those who successfully participated in 2011.

    CMS must submit a Report to Congress on the Physician Compare Web site by January 15, 2015. CMS is authorized to establish a demonstration program by January 1, 2019, to provide financial incentives to Medicare beneficiaries who are furnished services by high quality physicians. CMS held a town hall on Oct 27, 2010 to solicit input from stakeholders.

    RPA's Role
    AMA submitted comments to CMS on the proposed rule.
    Incentives or Adjustments N/A
    Resources Available/ Participation Information Physician Compare Background Paper 
    AMA Comments on Physician Compare Website  (see page 13)
    AMA Comments on October 27, 2010 Town Hall Meeting 



    Project Name
    CMS Quality Incentive Program (QIP) 
    Description

    Implements a quality incentive program (QIP) for Medicare outpatient ESRD  providers and facilities with payment consequences beginning January 1, 2012. The proposed ESRD QIP would reduce ESRD payments by up to 2% for dialysis providers and facilities that fail to meet or exceed a total performance score for performance standards established with respect to certain specified measures.

    Status

    Year 1 includes 1 hemodialysis adequacy measure and 2 anemia management measures. Although QIP payment reductions do not occur until Jan. 1, 2012, the performance period would need to occur before 2012 to allow enough time for claims processing and to evaluate facilities’ performance.
     
    The final rule was issued December 27, 2010.

    RPA's Role
    RPA submitted comments on the proposed rule in Sept 2010.  The comments address the importance of maintaining budget neutrality in the QIP program, reducing the maximum first-year penalty to one percent, and the impact of the program on small dialysis facilities, among other issues
    Incentives or Adjustments

    Facilities that do not meet or exceed performance standards will be subject to a payment reduction up to 2 percent. ESRD QIP payment adjustments will apply to payments under the ESRD PPS for outpatient maintenance dialysis items and services furnished to Medicare patients by ESRD facilities between Jan. 1, 2012 and Dec. 31, 2012.

    Resources Available/ Participation Information QIP Final Rule 
    CMS Overview of ESRD Quality Improvement  


    Project Name
    Maintenance of Certification - ABIM  
    Description
    Maintenance of Certification promotes lifelong learning and the enhancement of the clinical judgment and skills essential for high quality patient care. To become certified in the subspecialty of Nephrology, physicians must:

    At the time of application, be previously certified in internal medicine by ABIM; Satisfactorily complete the requisite graduate medical education fellowship training; Demonstrate clinical competence in the care of patients; Meet the licensure and procedural requirements; and Pass the Certification Exam in Nephrology.

    Status
    Every 10 years, internists and subspecialists certified in or after 1990 renew their certificates through ABIM's Maintenance of Certification program. Candidates must be credentialed, pass a secure examination, and earn a total of 100 points of self-evaluation in medical knowledge and practice performance.
     
    This structure consists of four components, each designed to assess important physician characteristics: professionalism (Part I), self-assessment and lifelong learning (Part II), cognitive expertise (Part III), and performance in practice (Part IV) which includes Approved Quality Improvement (AQI) programs. ASN offers the Nephrology Self-Assessment Program (NephSAP), where physicians can earn points.

    The Accountable Care Act (ACA) requires a mechanism whereby an eligible professional may provide data on quality measures through a maintenance of certification program (MOC) operated the American Board of Medical Specialties (ABMS) or an equivalent program. MOC Programs wishing to enable their members to be eligible for an additional PQRS incentive payment for the 2011 Physician Quality Reporting System will need to go through a self-nomination process by January 31, 2011.
     
    Rules concerning MOC for 2012 were included in the proposed Medicare Fee Schedule released July 1, 2011.

    RPA's Role

    Ongoing monitoring and collaboration with ASN. Nephrology Self-Assessment Program Modules is being developed by ASN.

    Incentives or Adjustments Physicians who satisfactorily report PQRS measures for 2011 can qualify for an additional .5% MOC incentive for 2011 if certain requirements are met.
    Resources Available/ Participation Information

    Overview of Maintenance of Certification 
    Practice Performance Modules 
    Nephrology Blueprint 
    ASN Nephrology Self-Assessment Program (NephSAP)
    PQRS and MOC (CMS)  
    MOC Guide for Nephrologists