With the launch of the Merit-based Incentive Payment System (MIPS), hundreds of thousands of U.S. clinicians will face new reporting requirements. Participation in a registry, a familiar quality improvement activity for many cardiology programs, could provide a solution.
New requirements & challenges
Regulations issued by the Centers for Medicare & Medicaid Services (CMS) pursuant to the Medicare Access and CHIP Reauthorization Act outlined Medicare’s Quality Payment Program (QPP), a complicated set of rules that requires clinicians to begin participating in one of two new payment pathways this year or face reimbursement penalties starting in 2019. More clinicians will be enrolled in MIPS vs. the other pathway, known as Advanced Alternative Payment Models (APMs). MIPS requires reporting in four categories: Quality, Cost, Improvement Activities and Advancing Care Information. MIPS-eligible clinicians who do not report any data will automatically lose 4 percent of their total Medicare reimbursement in 2019, and the stakes will go up each year, potentially amounting to a 9 percent loss.
One challenge for all physicians and their teams is to develop systems that help fulfill the QPP’s reporting requirements with minimal burden. In other words, how can we do what is required, delivering accurate and meaningful information to CMS, without neglecting our responsibility to care for patients, train the next generation of clinicians, conduct research and complete our administrative duties—ideally, without adding more work-hours to our schedules?
Leveraging an existing tool
For many cardiologists, an effective, efficient approach to reporting quality measures data is to take advantage of the registries at our disposal. In 2014, CMS began designating registries that collect medical and/or clinical data for patient and disease tracking to foster improvement in quality of care as Qualified Clinical Data Registries (QCDRs). A QCDR allows clinicians to report on specialty-developed measures that are robust and uniquely geared to their area of practice, thus fulfilling CMS reporting requirements while closely tracking the quality of their practices.
MIPS-eligible nuclear cardiology clinicians may opt to participate in the American Society of Nuclear Cardiology ImageGuide Registry. With its exclusive focus on concerns germane to nuclear cardiology, such as appropriate use, imaging protocols and report turnaround time, the ImageGuide Registry meets the unique needs and priorities of imaging specialists. In brief, ImageGuide gets granular about the details that truly impact nuclear cardiology practice without getting bogged down in measures mostly irrelevant to imaging. Currently, the MIPS mandate is to report on 50 percent of studies per year. Therefore, using a nuclear cardiology-focused QCDR results in a smaller, more manageable requirement while completing one obligation necessary to avoid a penalty.
As the cardiovascular community moves forward with the new value-based models for performance evaluation and reimbursement, it will be essential to develop effective tools that support efficient completion of requirements. Some tools, such as registries, are proven and available to us now.
Raymond Russell, III, MD, PhD, is director of both Nuclear Cardiology and Cardio-Oncology at the Cardiovascular Institute at Rhode Island Hospital; associate professor of medicine and program director of the cardiology fellowship program at the Warren Alpert Medical School of Brown University; and the 2017 president of ASNC.