On March 11, the Measure Applications Partnership (MAP) announced it does not recommend the Asthma/COPD Episode-Based Cost Measure for inclusion in the Merit-based Incentive Payment System program. MAP is a National Quality Forum-convened partnership that provides input to the Centers for Medicare and Medicaid Services on the selection of performance measures for federal programs.
MAP’s recommendation is based in part on the Advocacy Council’s comments to CMS about the measure. The College agrees with MAP’s recommendation; in our comments, we asked CMS to delay implementation of the cost measure for at least a year to allow for further testing and review.
The Advocacy Council reviewed the measure during CMS field testing last year. The College worked with allergy practices and a workgroup of College asthma experts to analyze field test reports and answer eight clinical questions related to the proposed Asthma/COPD cost measure. The College also provided detailed feedback on measure specifications and the Field Testing Measure Report. In general, the College found the new cost measure to be overly complex and patient attribution to be suboptimal.
If implemented, the Asthma/COPD cost measure will directly impact allergists participating in MIPS. The cost category makes up 20% of the MIPS score in 2021 and is scheduled to increase annually, so it’s important that the new measure accurately reflect patient costs attributed to allergists. Cost measures are calculated using claims data, and no data submission is required from clinicians.
The Asthma/COPD Episode-Based Cost Measure is described as follows:
The Asthma/COPD cost measure evaluates a clinician group’s risk-adjusted cost to Medicare for patients receiving medical care to manage asthma or COPD. The measure score is a clinician group’s weighted average of risk-adjusted cost for each episode attributed to the clinician group, where each episode is weighted by the number of assigned days during the episode. This chronic measure includes services that are clinically related and under the reasonable influence of the attributed clinician group. Services are assigned during an Asthma/COPD episode, which is a portion of the overall time period of a clinician group’s responsibility for managing a patient’s asthma or COPD. Medicare beneficiaries enrolled in Medicare Parts A and B during the performance period are eligible for the measure.
In response to College and other stakeholder comments, CMS made the following refinements to the cost measure:
| Refinement Type | Asthma/COPD Refinements |
|---|---|
| Service Assignment | Added services:
Removed services:
|
| Measure-Specific Risk Adjusters (in Addition to HCCs) | Added the following risk adjustors:
Edited the following risk adjuster:
|
The MAP evaluated the candidate measure and ultimately did not recommend the measure for rulemaking “with potential for mitigation … contingent on further evaluation on impact points for actionability demonstrating the connection between upstream medical interventions and downstream costs, as well as NQF endorsement.” The MAP also questioned the data’s reliability based on the number of cases and encouraged the agency to ensure that appropriate reliability thresholds are met.
CMS has the final word on whether to include this measure in MIPS but will consider the MAP’s recommendation, in addition to stakeholder feedback. If CMS includes the measure in the upcoming 2022 Medicare Physician Fee Schedule/Quality Payment Program proposed rule, the public will be afforded an opportunity to comment on the Asthma/COPD Episode-Based Cost Measure.
Stay tuned to the Advocacy Council for updates on this topic. The Advocacy Council – we have you covered.
