QCDR and Registry Reporting Frequently Asked Questions
How do I identify quality and improvement activities within a QCDR?
While AANA staff are pleased to discuss the options that CRNAs have with regards to achieving more MIPS points to improve your overall MIPS composite score, the AANA cannot determine which measures may or may not apply to your specific practice needs. It is up to the individual clinician or group to determine which measures are eligible to your practice. Each QCDR is responsible for their measures and data specifications, which vary by vendor. To begin planning, CRNAs are encouraged to review the list of Anesthesia-related QCDRs to review the measures offered by each vendor as soon as possible. In recognizing that time is needed to plan for quality and improvement activity reporting, CMS is making efforts to approve QCDR measures prior to the start of the calendar year. CMS does not post QCDR measure specifications on their website; therefore, contact your preferred QCDR to obtain their measure specifications.
How is data collected and submitted to a QCDR or registry?
How much time and effort does it take to participate in a QCDR or registry?
The amount of time you will personally be involved with quality reporting will depend on how much support staff you have accessible to you. While the AANA does not know what the exact time and financial burden MIPS reporting has on CRNAs, we do know that it can be substantial, especially for solo or small group practices. In a 2016 survey study published in Health Affairs by Casalino et al. respondents indicated that physician practices spent an average of 15.1 hours per clinician per week reporting external quality measures. Physicians themselves spent an average of 2.6 hours per week. While the study is not specific to the Medicare MIPS reporting program and the use of a registry or QCDR, the time reported by practices was staggering.
According to CMS Table 58 of the Quality Payment Program CY2018 Final Rule, CMS estimates the total annual burden hours at 9.1 hours per practice if the clinician reports using a registry or QCDR for MIPS quality reporting. In addition, the total annual burden cost was estimated at $851 for personnel time which does not include registry/QCDR subscription and additional service costs. The extent to which this time and cost burden reflects actual CRNA burden is up for debate. Participating in the QPP can be both a timely and costly endeavor—especially for those in solo or small group practices.
I am a solo provider and/or in a small group—where can I find additional help?
The AANA is always here to help. We can assist you with understanding the rule set forth by the MACRA and the requirements outlined by the Quality Payment Program, and provide you the resources that CMS has put forward for the current reporting period. We know that many terms and eligibility criteria within the MIPS program can be confusing. Therefore, the AANA is here to help clarify whether you qualify for special status, exceptions, reweighting or potential bonuses with regards to individual and group reporting.
The AANA recognizes that quality reporting can be a burden for individuals and small groups with limited human capital. Many QCDRs offer additional services at an extra cost to assist providers with issues such as data entry, chart abstraction, medical record extraction, spreadsheet manipulation, and general reporting. In some instances, CRNAs may need pay for additional support services through their registry or QCDR to assist with data entry and MIPS compliance. Because the AANA is not able to provide guidance or assist CRNAs with regards to data entry or data validation issues for any specific vendor service, we suggest that you take an inventory of your quality reporting support staff and technical needs.
How much does it cost to participate in a registry or QCDR?
CMS did not include QCDR subscription costs in their burden analysis because vendor costs vary; however, for anesthesia-related QCDRs base subscriptions range from $50 to $300 per provider. Additional QCDR full service assistance products to support solo or small provider practices range from $500 to $700 per provider. Depending on your needs, QCDR participation can be costly.
Who should I contact if I have questions about a specific QCDR or registry vendor?
Please directly contact the QCDR or registry. The AANA cannot address specific questions about vendor processes such as registration, data submission, data validation, or other technical questions. Please contact the vendor directly.
How does the AANA choose QCDRs and/or registries for AANA member discounts?
The AANA does not endorse any vendor or product, but the AANA does make a good faith effort to try to identify QCDR services that treat CRNAs with respect, value their business, and have developed a quality reporting business model that does not knowingly or purposefully make anesthesia provider distinctions.
Please note that the AANA cannot guarantee that these services will be available or that the vendor will be successful in uploading provider files during the submission period. Subsequently, the AANA cannot guarantee an eligible clinician's success in providing data for the program. According to CMS, successful submission is contingent upon following the MIPS program requirements, the timeliness, quality, and accuracy of the eligible clinicians’, group's, and/or virtual group’s data provided for reporting, and the timeliness, quality, and accuracy of the vendor.
How do I submit a complaint about the services provided by a QCDR or registry vendor?
While the business agreements through the AANA Member Advantage Program are relationships that provide AANA members with discounts for products or services, the AANA believes in providing feedback to our AANA Member Advantage Program partners. You may email your concerns to firstname.lastname@example.org. We will provide your comments to the vendor.
What has the AANA done to help prepare me for MIPS and the Quality Payment Program?
The AANA Research and Quality division reviews new proposed rules, final rules, and creates educational materials to help CRNAs stay abreast of the issues. We continue to create new educational materials for CRNAs ranging from Intro-videos, high-level fact sheets, and in-depth FAQs. We know that there are many terms and eligibility criteria within the MIPS program that can be confusing; therefore, the AANA is here to help assist you understand the program with regards to special status, exceptions, reweighting, benchmarking, MIPS scoring, and/or individual and group reporting.