eCQMs for ACOs: Recommendations
from the NAACOS Digital Quality Measurement Task Force

The NAACOS Digital Quality Measurement Task Force was established to identify key obstacles that must be addressed to ensure a successful transition to electronic clinical quality measures (eCQMs) and digital quality measures (dQMs) for ACOs. This paper recommends the MSSP program-wide pay-for-performance implementation of eCQMs should not move forward without proof-of-concept of both technical feasibility and the impact of the shift to all-payer/all-patient measurement that accompanies eCQM reporting. CMS must also consider future dQM goals and how ACO eCQM requirements fit into that larger goal. Other recommendations highlighted in the paper include: 

• CMS must not move forward with the all-payer requirement for eCQMs and MIPS CQMs when applied at the ACO level 
• Electronic Health Record (EHR) certification criteria must support ACOs in what they are required to achieve for electronic clinical quality and digital quality measurement 
• CMS must identify an alternative pathway to transmit data in a standardized way to enable successful patient matching, such as use of a national patient identifier or revisions to QRDA I formats
• CMS must provide the industry with greater standardization of data to assist in the highly burdensome process of data mapping and other workflow changes that will be necessary to transition to eCQMs and dQMs 
• CMS should allow for alternative data completeness standards for ACOs reporting eCQMs, or allow for exceptions/exclusions 
• CMS should provide policy incentives to help offset the enormous initial and ongoing costs associated with transitioning to eCQMs and dQMs, including making clinical quality measures pay-for-reporting, ensuring shared savings are not at risk, and/or setting alternative financial benchmarks for those who voluntarily test eCQM and dQM reporting