Participate in CMS HF Episode-Based Cost Measure Field Testing

The Centers for Medicare and Medicaid Services (CMS) and its contractor, Acumen LLC, are currently field testing several episode-based cost measures, including a chronic condition-based episode for the ongoing management of heart failure (HF) patients, through Feb. 25. The HF cost measure was developed with input from various specialty societies and ACC members.

The new episode is calculated with Medicare Parts A and B fee-for-service claims data, and therefore does not involve additional data submission by clinicians. Field testing is an opportunity for stakeholders to learn about the measure and provide feedback on draft specifications. Clinicians and groups with a case minimum of 20 episodes during the 2019 performance period can access informational field test reports to review their performance on the draft measure and also have the opportunity to provide feedback.

ACC’s Partners in Quality Committee encourages stakeholder participation by reviewing your data and providing feedback via the provided survey. Critical aspects of the measure include attribution, coding, patient population, services provided, medications, and the overall scientific acceptability and validity of the measure. Acumen will consider the comments submitted and make potential refinements after the field testing period ends on Feb. 25.

CMS will then be poised to propose and finalize the cost measure for use in an upcoming Physician Fee Schedule annual regulation (most likely in 2022 for use in 2023), with subsequent potential use in the Merit-Based Incentive System (MIPS) and ties to Medicare payment adjustments.

The MIPS cost performance category is one of four performance categories. The cost category is becoming more critical as it will represent 30% of the total MIPS score starting this year, impacting your organization’s revenue. There is a dearth of available cardiology-specific cost measures in MIPS and other quality reporting programs. Beyond MIPS, the measure could also be adopted by private payers and state Medicaid programs.

How to Participate in Field Testing

Your participation is important as you have the opportunity to influence further refinements to the measure. The report data and associated files likely will provide interesting insights and perspectives on the cost of care you are delivering for your patients. It will also give you and your organization more experience in evaluating your costs, as other cost-based measures likely will be adopted by both public and private payers. Access instructions, measure specifications, survey questions, and other information are available on the MACRA Feedback webpage, under the “Wave 4 cost measure field testing” section. For additional information on the cost measure development process, read this JAMA Health Forum article.

For specific questions or to share your observations to better inform ACC’s position on the measure, contact Fareen Pourhamidi, MS, MPH, ( by Feb. 18

Keywords: ACC Advocacy, Reimbursement Mechanisms, Chronic Disease, Heart Failure, Medicare, Fee-for-Service Plans, Centers for Medicare and Medicaid Services, U.S.

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