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Myths of Medicare ACO Quality Reporting in 2025

As a Medicare Qualified Registry, we have the opportunity to participate in recurring Medicare seminars on various quality topics. Regarding Medicare ACO changes coming in 2025, here are a few myths regularly discussed by qualified registries.

Myth #1

Medicare ACOs can only do eCQM reporting starting in 2025

This is False. Medicare ACOs may report either eCQM or CQMs in 2025.

3 MIPS CQM Measures*

  • Quality ID #1 (NQF 0059): Diabetes: Hemoglobin A1c (HbA1c) Poor Control >9%

  • Quality ID #236 (NQF 0018): Controlling High Blood Pressure

  • Quality ID #134 (NQF 0418): Screening for Depression and Follow-up Plan

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*MIPS CQMs are the only solution for aggregating data across multiple EHRs as, unlike eCQMs, they have the flexibility to use data from multiple sources, including multiple EHRs, and do not require  ONC certification.

3 MIPS eCQM Measures

  • Diabetes: Hemoglobin A1c (HbA1c) Poor Control >9%

  • Controlling High Blood Pressure

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  • Screening for Depression and Follow-up Plan

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If your ACO is a single TIN with a certified (CEHR) single EHR, then you may submit this file via QPP portal

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If your ACO is comprised of multiple TINs and EHRs, then you will have barriers so far unresolved by Medicare:

  1. Duplication when you combine all the QRDA III files as not patient-level files. Duplication may be solved by instead using QRDA I files and combining those into a QRDA III for final reporting. 

  2. When submitting eCQM the ACO will need to enter an EHR identifier and Medicare has not determined which identifier to use from the multiple TINs and EHRs

  3. It is under review by Medicare if an ACO can aggregate the QRDA I into QRDA III.

Myth #2

70 % of Patients are in the denominator

This is False. 100% of patients from all payers are in the denominator. 70% is the required completeness factor. 

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The following question was submitted to Medicare QPP:

     May an ACO choose to submit for only 8 of their 10 TINs?

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Answer from Medicare:

     No, all providers must participate in quality reporting for 100% of qualified patients.

Myth #3

A Multiple TIN ACO is free to report eCQM

For eCQM reporting only ONE QRDA III file is uploaded to QPP portal. If your ACO is comprised of multiple TINs and EHRs, then you will have barriers so far unresolved by Medicare.

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  1. Duplication when you combine all the QRDA III files as not patient-level files. Duplication may be solved by instead using QRDA I files and combining those into a QRDA III for final reporting.

  2. When submitting eCQM the ACO will need to enter an EHR identifier and Medicare has not determined which identifier to sue from the multiple TINs and EHRs

  3. It is under review by Medicare if an ACO can aggregate the QRDA I into a QRDA III.

Questions to ask for your ACO

Will our Medicare ACO still be an ACO in 2025?

        If no, then perhaps the best option is to instead be preparing for a non-ACO quality program.

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