Personal Blog #30 … Medicare Quality Measures, Part II … 2/11/23

 

In my column posted on 11/4/22 … PB #29, “Medicare Quality Measures, Part l” … I wrote about a “quest” I was on to see if Medicare would consider making a doctor’s referral of an AD patient or caregiver to a support group qualify as a “quality measure.”  To briefly review, in response to my June article about support groups, a doctor had suggested that more doctors might refer AD patients and caregivers to support groups if referrals were considered Medicare “quality measures” … actions that would result in financial or other incentives for doctors to make such referrals.  I then described my unsuccessful efforts to reach someone at CMS … Centers for Medicare and Medicaid Services … who could give me information about this matter.  No email address was available for the head of CMS, Chiquita Brooks-LaSure, and no one contacted at CMS would give me her email address.

In late December, tired of waiting for a response from Medicare administrators I was able to email, I decided to try a hunch and sent an email to the head of CMS by using the same ID characteristics of email addresses for the lower level CMS administrators … first and last names or initials with periods and such, followed by the CMS email string of cms.hhs.gov.  Much to my surprise, within one day I received a detailed response from a high ranking CMS official who said my email to Brooks-LaSure was referred to him.  Aside from being very helpful, the official also provided me with websites to find additional information and wrote, in part:

“I directed your most recent email to our group of experts on quality measures, called the Quality Measurement and Value-Based Incentives Group (QMVIG) within the Center for Clinical Standards and Quality (CCSQ). You have definitely gotten to the right place to make sure your input is being submitted and that you’re getting the information from the best source.  I checked before I left for the holiday last week, and they were about to get back to you.  So you should hear from them soon.  I’ll follow up there again, and I’m sure they will respond back more fully with more robust information but … there are potentially payment incentives for our quality programs.”

I was very excited with this response and followed up by reading information on websites provided by the senior advisor.  However, a month went by with no response from QMVIG, so I wrote again to the CMS official in Ms. Brooks-LaSure’s office.  Within 48 hours I received a detailed response from an administrator of QMVIG.  Here are excerpts of that response to my email, specifically to three questions I raised:

“1. Would there be a specific billing or reimbursement advantage for doctors who would report using such a Medicare quality measure?  Potentially. Quality measures are commonly used in quality reporting programs or value based purchasing programs which seek to revise our payment systems by focusing on high value care (high quality/low cost). Depending upon the care setting, a program may apply penalties or bonuses based on provider performance on quality metrics. Some areas where Medicare does have payment is on caregiver health risk assessment through CPT code 96161. Additionally, through Medicare’s cognitive assessment and care plan services CPT code 99483, clinicians can refer people with suspected or diagnosed dementia to social services (such as support groups) and determine caregiver willingness to furnish care: https://www.cms.gov/files/document/cognitive-assessment-care-plan-services-cpt-code-99483.pdf

2. Would there be any other specific advantage to doctors who would report using such a Medicare quality measure? Other advantages include the ability to share performance information on measures with the public, which can be used as consumer tools when selecting a provider and leveraging results of quality measurement to identify areas where there is room for quality care improvement.

3. If the answer to questions 1 and/or 2 is yes, what would be my next step in trying to have Medicare consider AD support group referrals as "quality measures." It is a long process to have something be considered for a quality measure, and usually involves having a measure developer who has experience developing a measure – as quality measures used in federal programs require strict definitions, specifications, and testing for validity and reliability. However any measure by any developer may be submitted to CMS for consideration. Please see the Measure Blueprint for more information on this process (https://mmshub.cms.gov/blueprint-measure-lifecycle-overview). The measure would then be submitted to a consensus-based entity for endorsement, such as the National Quality Forum (https://www.qualityforum.org/what_we_do.aspx). The measure ultimately needs to be submitted to the Measures Under Consideration list. Information on the pre-rulemaking process can be found here https://mmshub.cms.gov/Pre-Rulemaking-Resources.”

My initial response to this administrator’s email, which also included a lot more relevant information, was that the CMS bureaucratic process for something to become a Medicare “quality measure” was a navigational process beyond my capabilities.  After checking out the websites and familiarizing myself more with the bureaucratic hoops I’d have to go through to make my quest successful, my initial response was confirmed.  I emailed the QMVIG administrator telling her that I now planned to contact an advocacy organization with the resources and expertise to deal with the CMS bureaucracy …perhaps AARP, The Alzheimer’s Association, or UsAgainstAlzheimer’s … since, as the administrator noted, “it is a long process to have something be considered for a quality measure, and usually involves having a measure developer who has experience developing a measure.”  My experience with educational and non-profit organizations is that they almost always hire or already have on staff one or more specialized individuals with the precise experience necessary in order to apply for state or federal grants in their field, and this quality measure quest seems to be much like a state or federal  grant application process.  I would expect a large AD advocacy organization to have people with such experience.

I plan to forward what I have learned to one or more AD advocacy organizations and hope one of them will pursue this quest to have CMS recognize doctor referrals to AD support groups as quality measures.  Then, perhaps, more people with AD and their caregivers will learn more about support groups and benefit from attending such groups.