2024 MSR Preliminary Assessments

The AMA does not support removal of Age Appropriate Screening Colonoscopy measure from the MIPS program. The goal of 0039 is to eliminate inappropriate screening colonoscopies, and the measure assesses eligible clinicians routinely performing screening colonoscopy, including those doing lower volumes, to determine if unnecessary screening of the elderly is being performed. Therefore, we recommend maintaining the measure in this program as it focuses on a vulnerable population and specifically addresses overuse of colonoscopy, thereby improving cost and resource efficiency.

We also do not believe MIPS performance data is an accurate assessment to determine whether this measure was topped- out and CMS’ analysis was insufficient to make the determination. CMS’ analysis was based on one year of benchmarking data following the substantive changes made to the measure specification in PY2022. The amount of time to verify the extremely topped-out status should be based on multiple years, not one performance year cycle, and no other multi-year data was used to validate the topped-out status or extremely topped-out status, which typically occurs over multiple performance year cycles. Furthermore, 0039 has been designated by CMS as a high-priority measure and as the only colorectal cancer screening measure that specifically addresses the vulnerable population of older adults. Other more general conditions such as screening for Body Mass Index (BMI) and blood pressure are also standards of care where every patient is weighed and has their blood pressure checked at every eligible contact with a provider; however, CMS continues to include the measure in multiple specialty sets regardless of the performance rates.

Furthermore, the implications for removal of this measure are greater than just reducing the number of reportable measures in the MIPS program. Measure 0039 is one of six measures included in the GIQuIC qualified clinical data registry (QCDR) measure set, three of which are QPP measures and three of which are GIQuIC QCDR measures. All six of these measures look at physician performance on screening and surveillance colonoscopy and support meaningful and feasible performance measurement of clinicians addressing colorectal cancer prevention. It is the six quality measures that make up the GIQuIC QCDR Measure set that balance the only specialty-specific cost measure included in the candidate GI Care MVP, the Screening/Surveillance Colonoscopy episode-based cost measure.

00039-01-C-MIPS Age Appropriate Screening Colonoscopy (QID 439)

Thank you for your consideration of our comments submitted on 31, 2024, in support of this measure. While CMS has recommended that QID 439 be retired from the Merit-based Incentive Payment System (MIPS), stating the quality action being measured has become standard of care, based upon MIPS performance data, and thus has limited opportunity to improve clinical outcomes, our societies do not agree with the recommendation to remove QID 439 from the MIPS program.

The recommendation was based on one year of benchmarking data following the substantive changes made to the measure specification in PY2022. The amount of time to verify the extremely topped out status of the measure is too limited given that the recommendation was made based on one performance year cycle and no other multi-year data was used to validate the topped-out status or extremely topped-out status which typically occurs over multiple performance year cycles. Furthermore, this measure has been designated by CMS as a high-priority measure and is the only colorectal cancer (CRC) screening measure that specifically addresses the vulnerable population of older adults. Other more general conditions, such as screening for Body Mass Index and blood pressure, are also standards of care where every patient is weighed and has their blood pressure checked at every eligible contact with a provider; however, they continue to remain in multiple specialty sets regardless of their performance rates. 

The goal of QID 439 is to eliminate inappropriate screening colonoscopies. This measure assesses eligible clinicians routinely performing screening colonoscopy, including those doing lower volumes, to determine if unnecessary screening of the elderly is being performed. We believe this measure should continue to be available for clinician reporting via MIPS given that it focuses on a vulnerable population and specifically addresses overuse of colonoscopy thereby improving cost and resource efficiency.

The implications for removal of this measure are greater than just reducing the number of reportable measures in the MIPS program. QID 439 is one of six measures included in the GIQuIC QCDR measure set, three of which are QPP measures and three of which are GIQuIC QCDR measures. All six of these measures look at physician performance on screening and surveillance colonoscopy and support meaningful and feasible performance measurement of clinicians addressing CRC prevention. It is the six quality measures that make up the GIQuIC QCDR Measure set that balance the only specialty-specific cost measure included in the proposed GI Care MIPS Value Pathway (MVP), the Screening/Surveillance Colonoscopy episode-based cost measure.

The American College of Radiology published a study using 2019 data analyzing the impact of the topped out and extremely topped out status of measures by specialty societies and found “A preponderance of topped out measures within a specialty’s available measure set will greatly impair that specialty’s ability to do well in MIPS given the potentially capped scoring for those reporting such measures, as well as the eventual inability to report such measures at all as they become phased out. In this regard, variation between specialties in the preponderance of topped out measures may predispose certain specialties to be more likely in succeeding or failing under MIPS (https://www.jacr.org/article/S1546-1440(19)31008-7/fulltext) and gastroenterology continues to be one of those specialties impaired by this policy given the limited number of measures specific and important to gastroenterologists.

There is significant ambiguity in the policies related to the methodologies used when determining if a measure is extremely topped out that seemingly circumvents the system of checks and balances needed to ensure accountability. In the case of measure QID 439, a recommendation was made following one year of benchmarking data and during a period where many eligible providers elected for the extreme and uncontrollable circumstances option to meet their reporting requirements. Furthermore, the standard of care argument used seems to be selectively applied and biased in favor toward primary care or general medicine. As such, our societies oppose retirement of QID 439 Age Appropriate Screening Colonoscopy from the Quality Payment Program, including removal from the Gastroenterology specialty measure set, and ask that this measure be given an appropriate glidepath for removal, so gastroenterologists have time to determine an alternate meaningful measure on which to assess their practice and report.

Submitted by Eden Essex on behalf of:

American College of Gastroenterology

American Society for Gastrointestinal Endoscopy