NEW YORK (360Dx) - With less than six months before the first reporting deadline of the Merit-based Incentive Program, or MIPS, the College of American Pathologists has launched a registry aimed at helping pathologists maximize merit-based bonus pay and avoid penalties.
Called the Pathologists Quality Registry, the reporting tool is the first pathology-specific Qualified Clinical Data Registry, or QCDR, approved by the Centers for Medicare & Medicaid Services, CAP leaders said.
The timing of last week's launch enables pathologists to use the reporting tool for the first MIPS reporting deadline. MIPS streamlines three historical Medicare programs – the Physician Quality Reporting System, or PQRS, the Value-based payment Modifier program, or VM, and the Medicare Electronic Health Record Incentive program, also known as Meaningful Use – into a single payment program that is performance-based. The year 2017 is the first MIPS performance period, or period for which data is being collected, and participating providers must submit their 2017 MIPS data to CMS by March 31, 2018.
Due to the two-year lag in adjustments, 2017 data will determine physicians' merit-based pay bonuses or penalties for 2019. Physician could face 4 percent bonuses or 4 percent penalties based on their performance in the program in 2019,with bonuses and penalties rising later years.
For CAP, the registry is intended to ensure that pathologists making the transition to MIPS are able to quantify their work in a way that will maximize reimbursements, according to Jonathan Myles, a pathologist at Cleveland Clinic and member of the CAP board of governors.
"Payment now is not just about providing services — it’s about providing high quality service. All of us in our practices have stretched finances, and they are being stressed," Myles, told an audience at the CAP17 meeting last week in Maryland. "We want to be rewarded for the quality work we have been doing for a long time. The registry allows us to capture that work to make sure we are not leaving any money on the table that we are entitled to."
The Pathologists Quality Registry includes six new CMS-approved metrics for measuring pathology quality that are exclusive to CAP's registry. The new metrics will be offered in addition to eight pathology-specific measures previously developed by CAP that are currently part of CMS' Physician Quality Reporting System, or PQRS.
"We were looking for measures that would allow as many of the pathologists who were going to be participating in the MIPS program to report, so we needed to think of measures that impact a large number of patients and a large number of pathologists," Emily Volk, vice chair of CAP's council on government and professional affairs, said in an interview.
The six new measures cover protocols for endometrial cancer resection, kidney resection, intrahepatic bile duct carcinoma resection, liver resection, and pancreas resection, as well as a measure for turnaround time for standard biopsies. The cancer protocol measures are comparable to checklists that detail the elements required to be completed for each procedure, Volk said. The protocol measures are similar to the pathology-specific measures that CAP developed for CMS' PQRS, which included protocols for other diseases, such as melanoma and breast cancer.
The turnaround time metric, however, is a new measurement type that represents a new way of assessing pathology performance.
"It's the kind of metric that without our registry would not have been previously reportable," Volk said. "It's not the type of information that would be easily pulled out of claims-based data."
Historically, CAP's efforts at establishing measures for merit-based pay have been very successful, Volk noted. The performance metrics that are part of CMS' PQRS are "near being topped out" in terms of successful completion by participating pathologists, she said.
Measuring quality without patient contact
For pathology, measuring performance must be approached differently than for many other specialties because of pathologists' behind-the-scenes roles in patient care, according to Volk.
"Appropriately, when lawmakers were thinking about how they would measure quality for physicians they generally were thinking about more classically patient-based physicians," Volk said. "We advocate for the specialty. When the legislature was deciding on language to put in the statute, we were able to work with lawmakers to make sure they were considering physicians like pathologists who are not traditionally patient-facing."
As a result, pathologists have a different formula by which they are evaluated under MIPS than most other physicians. In 2017, the majority of physicians participating in MIPS will be evaluated on measures in three categories: quality, improvement activities, and advancing care information. Since most pathologists do not see patients, 85 percent of the pathologists' MIPS score will be composed of quality measured and the remaining 15 percent will be based on improvement activities, Volk said. A fourth MIPS category, resource utilization, will be introduced in 2018, for both patient-facing, and non-patient-facing doctors.
In addition, of the 100 improvement activities that can be used as MIPS measures, CAP has identified only 17 that apply to pathologists, Volk said. CAP's registry highlights those pathologist-specific activities. Examples include improvements that contribute to more timely communication of test results; use of a QCDR (such as the Pathologists Quality Registry) to generate feedback patterns and treatment outcomes; and providing specialist reports back to the referring physicians, Volk said.
The Pathologists Quality Registry also includes a dashboard by which pathologists will be able to benchmark their performance against their peers in the industry.
"It provides pathologists who sign up for it with a feedback loop, so they can understand how they are doing throughout the year, prior to making a submission to CMS," Volk said.
The dashboard will enable pathologists to monitor the performance measures they have completed, use basic analytics and interactive tools, and generate reports that measure their performance against others who are participating in the registry and against CMS benchmarks, according to Volk.
Pathologists can select which measures they would like to report to CMA, and the Pathologists Quality Registry will help them select which metrics would be best for them to report, Myles explained at the CAP meeting.
Developed in partnership with FIGmd, a company that specializes in integrating electronic health records with registries, the Pathologists Quality Registry is designed to integrate easily with pathologists' billing and lab information, making it easier to report, Volk said. The product is free for 2017, and for 2018 it will have an annual fee of $299 for CAP members and $799 for non-members.
Not all pathologists who participate in the MIPS will use a registry, but using a registry makes it easier for physicians to analyze their own reporting, Myles said. The alternative to using a registry is claims-based reporting, where data is reported at the time claims are submitted. Using a registry allows physicians to collate data throughout the year and report it at one time, he explained. In addition, CMS data suggests there is an added bonus to registry use.
"What is clear from CMS data across all specialties is that if you are a clinician who participates in these programs and you report through these registries rather than through a claims-based process, the folks that participate in the registry have a much, much higher successful rate of participation," Myles said. "The data is already there the registry participation will allow you to have a greater chance at success."
CAP data shows that MIPS has the potential to have a significant financial impact on the industry, Myles said. CAP estimates that $2.1 billion in Medicare payment is at stake over the next seven years in pathology alone, he noted.
"You can see, what we want to do as a specialty is keep as much money in pathology as possible, and this tool will allow us to do that," he said.
Meanwhile, another advantage of the registry is that it would help pathologists with the burden of regulatory compliance, Volk noted, adding the registry will continue to update as regulations evolve.
"It takes a practicing pathologist a fair amount of effort to keep up with all of these things, and these things change yearly," she said. "One of the things that CAP tries to do is make it as easy as possible to be successful as this program evolves."