As the ESRD QIP gets larger and more complex, questions come from dialysis community

“Is the QIP applicable to nephrologists?”

It was an odd question posed to Centers for Medicare & Medicaid Services staffers Jim Poyer, Tamyra Garcia, and Joel Andress during a Medicare Learning Network session last month on the forthcoming changes to the Quality Incentive Program for payment year 2019.

The answer, of course, is no. Congress is working on a new physician-specific QIP to debut in 2019: a set of quality measures will be tied to payment in the Merit-Based Incentive Payment program.

But there were plenty of other questions during that Jan. 19 session on the latest QIP requirements for dialysis providers. Every January, a new QIP cycle begins, and it is getting bigger and more complex. In fact, the process is getting complicated enough that CMS, upon the recommendations of the renal community, is developing an ESRD Measures Manual, to be released this year. If you have ideas on what the manual should contain to help make the QIP easier to understand, you can submit comments via jira.oncprojecttracking.org

More measures coming

CMS sees the QIP as a way to measure compliance and quality in the ESRD Program. It started with just two measures when it debuted in 2012; for performance year 2017, there will be 13 reporting and clinical measures––even after CMS consolidated four adequacy measures into one. That’s a lot of data, and CMS is using its CrownWEB collection system to capture the information among the more than 5,000 dialysis clinics in the U.S.

During the last round of proposed changes, comments from the renal community included the complaint that the QIP was getting too big, absorbing too many staff resources. What hasn’t been clearly defined is the true benefit of the QIP: has performance based on the quality measures improved important outcomes like reduced hospitalizations, lower mortality, and better quality of life? Recent data from reporting groups like the U.S. Renal Data System and PEER do show that mortality and hospitalizations have dropped, but it’s not clear if the QIP has influenced those positive results.

How the QIP works

Even though the program has been in place for four years the many questions posed during the MLN forum—like the question about physician performance and the QIP—still shows a lack of clarity on how the QIP works. During the de-briefing, CMS officials spelled out the QIP’s three-year cycle: the first year is recording the work done by clinics to meet the quality measures (thus every year in the cycle is a “performance year”); the second year is for CMS to evaluate and score that performance, and the third year is the payment assessment. Clinics can see up to a 2% hit on their composite rate if they fail to meet the agency’s total performance score for the quality measures. The score is based on both clinical (90% weight) and reporting measures (10% weight).

In between, CMS proposes changes to the program each year, and the renal community gets a chance to provide feedback. In general, CMS uses measures endorsed by the National Quality Forum, but not always.

Sometimes the news from CMS is about what measures it didn’t approve; for performance year 2017, for example, CMS decided not to push a measure that would have created an ultrafiltration rate or full-season Influenza vaccination reporting measure. CMS did revise technical specifications for its Standardized Readmission Ratio (SRR) clinical measure to exclude readmissions that occur within the first three days of initial discharge. Thus if a dialysis patient goes back into the hospital within three days of discharge, the clinic staff isn’t penalized. The agency also recognized that outliers—very sick patients—can thrown off a performance score. So the QIP will not be activated at clinics with less than 12 patients, and pediatric patients can be included in the mix.

CMS will answer any of your QIP-related questions. Send them to ESRDQIP@cms.hhs.gov. An audio recording and written transcript of the Jan. 19 forum is available at the MLN Connects National Provider Calls and Events webpage.