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5 Challenges Facing Digital Quality Measurement

Analysis  |  By Laura Beerman  
   April 14, 2022

The National Association of ACOs is the latest to respond to CMS electronic quality measure goals.

Which challenge to tackle first in digital quality reporting?

The National Association of ACOs (NAACOS) is one of many posing the question as CMS aims to "[t]ransform measures to fully digital by 2025." NAACOS announced that it "has launched a new task force, aimed at developing recommendations for how to successfully collect and electronically report on ACOs' quality of care through disparate health information technology (IT) systems."

In its press release, NAACOS noted the following digital quality measure challenges for the Medicare Shared Savings Program (MSSP) and other stakeholders:

  1. Interoperability. An abiding industry challenge requiring the collection, integration, and analysis of data from dozens of disparate EHR systems.
  2. Standardization. A key part of interoperability applies not only to data but quality measures themselves. Electronic clinical quality measures (eCQM) were a component of CMS' final Rate Announcement.
  3. Streamlining. CMS' Meaningful Measures program, now in Phase 2.0, will continue to target measure reduction and consolidation. Some ACOs have already done this work. A consolidated value-based care Star Rating from one MSSP—the Baylor Scott & White Quality Alliance—spans 50+ multipayer contracts and was featured in a January 2022 NAACO webinar.
  4. Unique ACO challenges. NAACOS reports that more than 75% of ACOs must navigate at least six EHR systems, with 37% managing 15 or more. NAACOS also cited the "unintended implications and consequences of mandating data reporting on total patient populations instead of just the MSSP," which has been the decade-long standard.
  5. Financial and operational changes. Achieving all the above by 2025 will require time, resources, and money, what NAACOS terms "significant investment by vendors, practices, and ACOs."

The NCQA response

NAACOs is not alone. In mid-2021, the NCQA responded to CMS' Meaningful Measures 2.0 announcement and Request for Information (RFI). Placing eCQM needs within the context of a pandemic that revealed just how vulnerable we are, NCQA Federal Affairs Director Eric Musser wrote:

"Now imagine this: It's 2025, and there's another pandemic—but this time, there's a solution to those issues. There's a solution because the federal government, with support from private industry, looked at the how the system failed in 2020 and asked, 'How do we build an infrastructure that ensures we'll never be caught flat-footed again?' "

NCQA's digital quality measures priorities include a "digital first" portfolio and measures that are "configurable, modular" and can be accessed and integrated via API and standards such as Fast Healthcare Interoperability Resources (FHIR).

Returning to NAACOS' response, Katherine Schneider—Digital Quality Measurement Task Force chair—noted: "[W]e know digital quality reporting in general is the direction we need to move in, but we need to get it right, ultimately for the benefit of the momentum of value-based care and for patients, including those cared for by safety net providers."

Laura Beerman is a contributing writer for HealthLeaders.


CMS' Meaningful Measures 2.0 initiative continues to draw industry support and response, most recently from the National Association of ACOs.

The organization cites unique ACO challenges related to digital quality measurement, including how new goals upend long-standing ones.

ACO financial and operational challenges join those common to all stakeholders, including interoperability and measure standardization and streamlining.

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