Clearing up Confusion about QRDA III Files
Many APMA members have shared that the QRDA III files provided to you by your electronic health record (EHR) vendors cannot be uploaded to the CMS Quality Payment Program (QPP) portal and are asking for APMA's assistance in understanding QRDA III files and their use for MIPS reporting.
The QRDA III file is the means for reporting electronic clinical quality measures (eCQMs). In order to successfully complete your reporting, you should be able to follow these three steps:
- Request your QRDA III file from your EHR vendor for the eCQMs on which you would like to report. Note: Your EHR system is only able to support the eCQMs for which they were certified, so be sure to check which measures your EHR system supports.
- Check the validity of your QRDA III file by going directly to the CMS QPP sandbox (not affiliated in any way with APMA) to upload your file and check its status: https://qpp.cms.gov/developers/conversion-tool-sandbox.
- If valid, upload your QRDA III file directly to the CMS QPP portal for reporting/submission: https://qpp.cms.gov/login. Note: There is no cost for submitting directly to CMS. Reporting to CMS in this manner is in no way related to and should not be confused with a registry. CMS only allows submission with QRDA III files created by certified EHRs.
As 2015 or 2014 Office of the National Coordinator for Health Information Technology (ONC)-certified EHR technology, your EHR vendor, according to the requirements of its certification, must be able to provide you with a valid QRDA III file for the 2018 reporting year. If your EHR is unable to provide this file, the vendor is in violation of its certification and should be reported to the ONC.
If you find you are unable to obtain a valid QRDA III file from your EHR vendor, you can follow the steps mentioned at www.healthit.gov/topic/certified-health-it-complaint-process. Contact APMA if you need assistance at 800-ASK-APMA or by emailing firstname.lastname@example.org.
Understanding eCQMs and MIPS Reporting
CMS has a wide range of quality measures, including eCQMs and registry measures, that you could choose to report. There are a number of factors that go into choosing which measures you would want to report, including the following. You may:
- decide on a certain reporting mechanism (claims, registry, EHR);
- choose which measures best fit your practice; or
- look at benchmarking data to help you decide which measures you will report.
With respect to benchmarking data, did you know that reporting the same measure via eCQM rather than via a registry may get you significantly more points for the same performance rate for that quality measure? These quality measures are scored based on how other users reporting the same measures perform. Since registry measures are "easy" to report on, they usually have much higher benchmarks and thus result in lower scores.
It is incumbent upon your EHR vendor to educate you about how to document appropriately to capture the data for eCQM reporting. Your EHR system is certified for certain eCQMs (there were 53 possible eCQMs for which to be certified in 2018). There are several eCQMs that podiatrists may choose to report, including the following:
- Tobacco Use: Screening and Cessation Intervention
- Body Mass Index (BMI) Screening and Follow-Up Plan
- Pneumococcal Vaccination Status for Older Adults
- Influenza Immunization
- Diabetes: Foot Exam
- Falls: Screening for Future Fall Risk
APMA works diligently to ease the burden of participation in government programs, including MIPS. APMA provides a mechanism for MIPS reporting to its members as a free benefit and will continue to do so for 2019. The new rules for 2019 allow you to submit both registry measures and eCQMs. APMA recommends you select the process that provides the broadest range of measures available, which is why the 2019 APMA MIPS App will include every relevant eCQM and registry (now called MIPS quality measures) measure available for you to report. Stay tuned for more information later this month.
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