Myths of Medicare ACO Quality Reporting in 2025

As a Medicare qualified registry, we have the opportunity to participate in recurring Medicare seminars on various quality topics. Regarding Medicare ACO changes coming in 2025, a few myths regularly discussed by qualified registries:

Myth: Medicare ACOs can only do eCQM reporting starting in 2025.

• Medicare ACOs may do either eCQM or CQM reporting in 2025. One of the primary differences between eCQM and CQM are the allowed data sources.

Myth: 70% of patients is the denominator

• 100% of patients from all payers is the denominator. 70% is the required completeness factor. The following question was submitted to Medicare QPP: May an ACO choose to submit for only 8 of their 10 TINs if this is 70% of the patients? Answer: No, all providers must participant in quality reporting for 100% of qualified patients.

Myth: A multiple TIN ACO is free to report eCQM

• For eCQM reporting only ONE QRDA III file is uploaded to QPP portal. If your ACO is comprised of multiple TINs and EHRs, then you will have barriers so far unresolved by Medicare 1) duplication when you combine all the QRDA III files as not patient-level files. Duplication may be solved by instead using QRDA I files and combining those into a QRDA III for final reporting; and 2) when submitting eCQM the ACO will need to enter an EHR identifier and Medicare has not determined which identifier to use from the multiple TINs and EHRs; 3) It is under review by Medicare if an ACO can aggregate the QRDA I into QRDA III.

The first question to ask: "Will our Medicare ACO still be an ACO in 2025?" If no, then perhaps the best option is to instead be preparing for a non-ACO quality program.

Kris Gates, CEO, Health Endeavors, 480.912.1209, [email protected]