The Centers for Medicare and Medicaid Services (CMS) and its contractor, Acumen LLC, are conducting a field test for eight episode-based cost measures before considering their potential use in the Cost performance category of the Merit-Based Incentive Payment System (MIPS) of the Quality Payment Program (QPP), starting as early as 2019. CMS and Acumen will be collecting information on the measures through a survey that will remain open until Nov. 20, 2017, at Noon ET.

While the Cost category does not currently count toward the MIPS score, CMS may raise the weight of the Cost category as high as 30 percent starting with the 2019 performance year under the current statute. Clinicians and groups will be measured on claims-based measures and any episode-based cost measures finalized through the rulemaking process. Each episode-based measure would assess the sum of the cost to Medicare for services performed by an attributed clinician or group of clinicians over a defined window. Three of the eight draft measures for review are especially relevant to cardiovascular care:

Cost Measures	Would Apply to	Episode Window
Elective Outpatient Percutaneous Coronary Intervention (PCI) Surgical procedure meant to place a coronary artery stent for heart disease in a non-emergent, outpatient setting	Clinicians who perform Elective Outpatient PCIs for Medicare beneficiaries during the measurement period	30 days post-trigger event
ST-Elevation Myocardial Infarction (STEMI) with PCI Acute medical condition captures the care of patients who present with STEMI, indicating complete blockage of a coronary artery, who emergently receive PCI as treatment	Clinicians who manage inpatient care of Medicare beneficiaries hospitalized during the measurement period for a STEMI requiring PCI	30 days post-trigger event
Revascularization for Lower Extremity Chronic Limb Ischemia Surgical procedure meant to alleviate symptoms of pain and difficulty walking associated with chronic limb ischemia; excludes patients who require emergent revascularization for acute limb ischemia	Clinicians who perform elective revascularization for lower extremity chronic critical limb ischemia for Medicare beneficiaries during the measurement period	30 days prior to trigger event through 90 days post-trigger event

ACC members were involved in the clinical subcommittees advising CMS and Acumen on the development of these measures. It is critical that all members identify issues with the measures before they are implemented by reviewing their reports and providing feedback through the following steps:

1. Access your unique Cost Measure Field Test Report or the mock report.

Solo practitioners and group practices who meet a 10-episode case minimum for at least one of the measures undergoing field testing will have a cost report showing their actual measure performance based on Medicare Part A and B fee-for-service claims data from June 1, 2016 – May 31, 2017. Field Test Reports can be accessed here using the Enterprise Identity Management (EIDM) account used to access your QRURs. If you think you should have a report but do not see one in your EIDM account, contact QPPCostMeasureTesting@ketchum.com and be prepared to share your TIN and EIDM account information.

Those who do not meet the 10-episode case minimum will not receive personalized reports, but are welcome to review and provide feedback on the mock report available for download (Excel File). Note that the mock report includes tabs on all eight episodes out for testing.

Reports include a summary page of your risk-adjusted cost performance relative to the national average; a breakdown of services utilized and cost by Medicare setting and service category (Appendix A); episode-level table for all episodes attributed to your TIN (Appendix B). Supplemental information on all measures is also available for download in this ZIP file from CMS.

2. Provide your feedback through this survey.

The survey should take approximately 20 – 30 minutes to complete, depending on the number of episodes you comment on and the level of detail you provide. Questions address the format and usability of the information provided in the report and the design of specific episodes. You are not required to provide comments on all measures, nor are you required to answer all the questions in the survey. You may also upload written comments in lieu of the survey questions. Comments can be submitted anonymously.

3. Share your feedback with the ACC. (Optional, but highly encouraged.)

The ACC will continue to advocate on behalf of members to urge CMS that valid, risk-adjusted episode group measures and actionable feedback reports must be in place if clinicians are to be held accountable for the cost of care under MIPS. E-mail comments or questions on the episode group field testing reports to MACRA@ACC.org, so ACC can communicate your feedback as part of our advocacy efforts.

If you are not familiar with measuring the cost performance of your practice or reading your past QRURs under the Value-Based Payment Modifier, reach out to your practice or service line administrator or quality reporting lead to help access and review the data or to complete the survey on your behalf. Read more information on the MIPS Cost Category. For more on the QPP, visit ACC.org/MACRA. E-mail QPPCostMeasureTesting@ketchum.com or MACRA@ACC.org with questions.

Keywords: Fee-for-Service Plans, Medicare Part A, Centers for Medicare and Medicaid Services, U.S., Outpatients, Medicare, Medicaid, Feedback, Percutaneous Coronary Intervention, Group Practice

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