For an agency that embraces values-based care, CMS is missing the mark when it comes to monitoring its own quality measures, finds a recent watchdog report.

The U.S. Government Accountability Office (GAO) published their September 2019 Health Care Quality report: “CMS Could More Effectively Ensure Its Quality Measurement Activities Promote Its Objectives.”

The report indicates that CMS isn’t doing a very good job tracking its funding or measuring how they are using said funds to meet its strategic objectives.

Quality Measures to Improve Value

One of the ways CMS is working to move payment toward value, improve patient outcomes, and reduce provider burdens is with their Meaningful Measures Initiative. Launched in 2017, it seeks to streamline quality measurement with 8 strategic objectives for CMS to adopt measures that:

• address high-impact measure areas that safeguard public health
• are patient-centered and meaningful to patients
• are outcome-based where possible
• fulfill program requirements
• minimize provider burden
• offer a significant opportunity for improvement
• address measure needs for population-based payment through alternative payment models
• align across programs and/or with other payers

But CMS doesn’t have procedures in place to ensure its quality measures meet its strategic objectives, finds the GAO report. Unfortunately, this “increases the risk that the quality measures it selects will not help the agency achieve those objectives as effectively as possible,” states GAO.

CMS Quality Measures Lead the Way

CMS has been leading the way in transitioning healthcare payments from the traditional fee-for-service model to value- based care. That is, a provider will receive Medicare payments adjusted by CMS based on customer satisfaction.

So the choices CMS makes about its quality measures reverberate through the healthcare industry because the quality measures directly impact the care that CMS beneficiaries receive.

Adjusting payments based on measured performance and shifting payments from hospitals with low quality measure scores has had some implications — mainly providers questioning CMS measures. Many providers and stakeholders believe:

• CMS measures aren’t good indicators of the quality of care patients received.
• They spend too much money and other resources on reporting data for these CMS quality measures.

CMS Quality Measure Deficiencies & GAO Recommendations

The Bipartisan Budget Act of 2018 provides the opportunity for GAO to review the CMS quality measurement activities. From funding activities to deciding how to use quality measures, here are some key takeaways from GAO’s review:

Key Finding #1

CMS lacks complete information on the amount of resources it has obligated for its quality measurement activities and how its allocation of those resources relates to its quality measurement strategic objectives. Specific findings include:

• CMS tracks quality measurement funding for specific appropriations.
• CMS holds on to a large amount of unobligated balances (money not used, but still available) for quality measurement activities.
• CMS hasn’t effectively tracked funding for activities related to its quality measurement strategic objectives.

GAO Recommendation:

CMS should maintain more complete and detailed information on its funding for quality measurement activities.

Key Finding #2

CMS lacks procedures to ensure that the decisions it makes to develop and use measures for its quality programs are consistent with those objectives. Specific deficiencies include:

• CMS uses a variety of methods in selecting Medicare quality measures for its programs.
• CMS lacks procedures that would make sure these methods line up with their quality measurement strategic objectives.
• CMS hasn’t put performance indicators in place to evaluate its progress in meeting these objectives.

GAO Recommendation:

CMS should establish procedures to systematically assess measures under consideration based on CMS’s quality measurement strategic objectives

Key Finding #3

CMS has not developed and implemented performance indicators to evaluate its progress towards achieving these objectives. Specific observations include:

• CMS hasn’t set indicators to measure its performance in meeting strategic objectives.
• CMS, instead, assesses the impact of its quality measurement activities by reviewing changes in providers’ reported performance on selected quality measures.

GAO Recommendation:

CMS should develop and use performance indicators to evaluate progress in achieving its objectives.

Takeaway: These findings “limit CMS’s ability to determine whether its allocation of resources and quality measurement decisions are optimal or whether changes are needed in its approach,” states GAO. The Department of Health and Human Services (HHS) concurred with GAO’s recommendations.

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