Monday Musings

I had given up on ever getting any wound care quality measures into PQRS. CMS wouldn’t consider measures without NQF endorsement, the NQF didn’t consider measures that were not in their specific categories (priorities that they get FROM CMS which also funds the work of the NQF), and even if we could find an NQF category we could use to submit some of our measures, even a process as well researched as diabetic foot ulcer off-loading couldn’t meet the NQF’s stringent evidence requirements (the trials were too small). In addition to which, we would need about $3 million dollars to develop and test enough quality measures. By 2013 I was done wasting my time on this hopeless task. And then suddenly, in December of 2013 I found buried in the 2014 Medicare Physician Fee Schedule legislation a new concept called the Qualified Clinical Data Registry (QCDR).

A QCDR is a CMS-approved entity that collects medical and/or clinical data for the purpose of patient and disease tracking to foster improvement in patient quality of care. But the major difference between a QCDR and a traditional PQRS Registry is that QCDRs are not limited to reporting measures within PQRS. A QCDR may develop its own quality measures and submit them to CMS for approval. Even though they are not part of PQRS, doctors reporting their quality data through that QCDR can get PQRS credit for using them. I couldn’t believe it. At last we had a mechanism by which we could develop our own quality measures. As the Executive Director of the US Wound Registry (USWR), we had been reporting quality data for physicians since 2008. But we’d always been limited to the measures within PQRS. Now we could develop our own. There was only one catch. I found out about this at Christmas of 2013 and the nomination paperwork with the fully developed measures was due January 31, 2014. After 7 years of making no progress we suddenly had 4 weeks to create up to 20 measures. The USWR partnered with the Alliance of Wound Care Stakeholders and initiated a series of conference calls with Alliance members to develop measures by the deadline, crafting 12 wound care quality measures which CMS accepted as part of the USWR QCDR in 2014.

This year, 2015, the Undersea and Hyperbaric Medical Society (UHMS) developed 6 hyperbaric related measures, and Nestle sponsored the development of a nutrition measure for patients with wounds. All of the measures in the QCDR are being developed as electronic Clinical Quality Measures (cCQMs). What does that mean? It means if you are using an EHR certified for stage 2 of meaningful use, you can download the eCQMs when they are available in April. You should be able to provide them to your EHR vendor and they should be able to “insert” the eCQM, allowing you to report wound care and hyperbaric specific quality measures and get PQRS credit for them.

So, here’s the bottom line on this. If you don’t participate in PQRS, you are going to lose about 6% of your Medicare revenue by 2017, possibly 10% with the Value Modifier. By 2018 nearly 30% of your Medicare payments will be linked to quality. If you use the traditional PQRS measures you will left reporting measures like medication reconciliation, BMI, and immunizations as indicators of the quality of your wound care practice.

Why not just pick anything to report? The problem is that performance on these measures is not just being used for PQRS. The data must be reported publicly so your name is going to be available on the internet for everyone to see how well you perform. Patients are going to select their doctors from this information. As wound care doctors we don’t want our quality of wound care to be judged by whether we recorded immunizations in our EHR. Measures are also being used to set payment rates by insurance companies and as a major component of salary negotiations.

By April 30, you should be able to find eCQMs on the USWR website. The USWR is a 501c(3) non profit organization that exists for the purpose of providing quality data to CMS on behalf of clinicians, developing wound and hyperbaric relevant measures, and providing data for comparative effectiveness research. Using the USWR QCDR for your quality reporting can not only help you avoid increasingly steep financial penalties for NOT reporting but also help create a data repository that can be used to establish the effectiveness of advanced therapies. It’s been a long journey.