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Physician Performance Measurement

A Nephrologist’s Guide to National Initiatives

As nephrology continues to move toward value-based care, it is important for nephrology practitioners to understand the components and key players in these programs. Value-based care incentivizes the quality of patient care over quantity, with the goal of outcome-based reimbursement. These programs may be implemented by CMS, states, and private payers.

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, measures have been used predominantly for quality assurance, quality improvement, and public accountability. Increasingly, however, private and public payers are using performance measures as preconditions for determinants of payment, including 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 MIPS.


 

PERFORMANCE MEASUREMENT ACTIVITIES AFFECTING NEPHROLOGY PRACTITIONERS



Measure Implementation

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



Project Name

Quality Payment Program

Description

An outcome of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)  in 2015, the Quality Payment Program (QPP) replaced existing programs such as PQRS, Meaningful Use and the Value-Based Modifier.

Status

Launched in 2017. Providers may participate in the Merit-Based Incentive Payment System (MIPS) or Advanced Alternative Payment Models (APMs). 

MIPS includes 4 components:

  • Quality Reporting
  • Promoting Interoperability (formerly Advancing Care Information)
  • Improvement Activities
  • Cost


Incentives or Adjustments

Eligible professionals who do not successfully participate in 2022 will face a 9% adjustment in 2024. Successful participation may result in an incentive payment. Providers may participate as individuals or as a group. 

RPA Tools

 

RPA has developed the RPA Guide to QPP Participation to assist providers in meeting the program requirements. The following sections are included in the Guide:

Resources Available/ Participation Information

 


QPP Resource Library
QPP Exception Information
QPP Help Desk
Resources for small practices
Qualifying APM Participant (QP) look-up tool
Submit data via CMS website (instructions
MIPS Value Pathways (MVP)

 

Voluntary Kidney Model Participants (CKCC) - 2021

CMS/CMMI announced on March 18, 2021 that they were granting relief to CKCC model applicants from MIPS; those practices should file the MIPS Extreme and Uncontrollable Exceptions Application, citing the fact that the COVID-19 pandemic led to the delay in the start of the KCC Model performance year.



Project Name

Dialysis Facility Compare Five Star Rating System

Description

DFC Five Star Ratings System is CMS’ effort to provide patients in dialysis facilities with an easy to understand summary of the quality data reported on the DFC website. Rather than compel patients to try and compare facilities by looking at numerous individual quality measures, the Five-Star system is an attempt to aggregate that information. It uses a forced bell curve.

Status

The DFC Five Star Ratings System went live January 22, 2015.

RPA's Role

 

RPA submitted comments to CMS in August 2014 regarding the absence of meaningful public review and comment process, assignment of the Star Ratings, use of the Standardized Ratio measures, and potential disruptions in continuity of kidney patient care.

Resources Available/ Participation Information

RPA FAQ on the Five Star Rating System
CMS presentation (July 2014)



Project Name

Care Compare Web Site

Description

CMS publicly reports Quality Payment Program (QPP) performance information for doctors, clinicians, groups, and Accountable Care Organizations (ACOs) on Medicare Care Compare Doctors and Clinicians profile pages and in the Provider Data Catalog (PDC). The performance information was previously reported on Physician Compare profile pages and in the Physician Compare Downloadable Database.

Status

Physician Compare website went live in 2013.

RPA's Role

AMA submitted comments to CMS on the proposed rule.

Incentives or Adjustments

N/A



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 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

The final rule was issued December 27, 2010.

RPA's Role

RPA submitted comments on the proposed rule in Sept 2010 and may submit comments during annual rule-making. 

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.

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.

 

 Status

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.

Starting December 1, 2021, nephrologists will have the option to take the Longitudinal Knowledge Assessment or they may continue to take the 10 year exam. 

 RPA's Role

Ongoing monitoring and collaboration with ABIM. 
The RPA QAPI MOC Program allows nephrologists affiliated with participating dialysis organizations to earn MOC credits for participating in monthly QAPI meetings.

Resources Available/ Participation Information

Overview of Maintenance of Certification
Nephrology Blueprint
ASN Nephrology Self-Assessment Program (NephSAP)
MOC Guide for Nephrologists
RPA QAPI MOC Program
ABIM Knowledge Assessment (LKA)
LKA FAQ

   
 

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), 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

 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 convenes regularly to make recommendations about whether KCP should support or oppose proposed facility-level measures The Kidney Care Quality Alliance (KCQA), funded by KCP, develops quality measures for used in the dialysis setting.

RPA's Role

 

RPA content experts participate in KCP including the measures workgroup and serve on KCQA.

Resources Available/ Participation Information

 KCP Overview

 

   
 

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 the 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.

RPA's Role

RPA was granted membership in NQF 12/2005. RPA is a voting member and provides feedback on proposed measures related to kidney care. RPA submitted measures during the 2015 call for renal measures and maintains measures in the NQF clearinghouse.

Resources Available/ Participation Information 

List of NQF-endorsed measures
RPA Appeal of Measure 2496 - Standardized Readmission Ratio (SRR) for Dialysis (2014)