ACMT ToxIC Qualified Clinical Data Registry
Frequently Asked Questions (FAQ) 1.0
What is a Qualified Clinical Data Registry (QCDR)?
A Qualified Clinical Data Registry (QCDR) is a Centers for Medicare and Medicaid Services (CMS) approved entity that collects medical and/or clinical data on behalf of clinicians for the purpose of improving the quality of care furnished to patients. Many national medical specialty societies operate a QCDR.
Is there a Medical Toxicology QCDR?
Yes. On December 29, 2017 The Centers for Medicare and Medicaid Services (CMS) approved the ToxIC Registry as a Qualified Clinical Data Registry (QCDR). Known as the ACMT ToxIC Qualified Clinical Data Registry (TQCDR™) this QCDR will provide an opportunity for medical toxicologists to report on a variety of medical toxicology quality measures. The TQCDR will serve as a platform for ACMT to report on medical toxicology measures to CMS akin to the American College of Emergency Physicians (ACEP) utilizing their Clinical Emergency Data Registry (CEDR) to report emergency medicine measures to CMS.
Why did ACMT Develop a Medical Toxicology QCDR?
Health care delivery is rapidly becoming value-based. Simply put, for medical toxicology to have a place at the table, particularly with bundled payments on the horizon, medical toxicology must demonstrate its value.
2017 marked the start of the fundamental shift from volume-based to value-based payment mandated by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). To align medical toxicology to this new value-based paradigm there are a number of important questions that need to be addressed:
- What value-added does medical toxicology provide to population base management?
- What community health benefit results from medical toxicology expertise and how much is the benefit?
- What data analytics are available to address these issues?
The development of the TQCDR and medical toxicology quality measures are an attempt to set benchmarks for medical toxicology practice that will then be tracked in our own QCDR. Participating in this program will hopefully provide meaningful data about how medical toxicology practice can add value to overall healthcare delivery.
What are the Benefits of Participating in the ToxIC Registry QCDR?
- Promote the highest quality of toxicological care for our patients.
- Chance to participate in a nationally recognized medical toxicology specific QI program
- Chance to participate in a Merit-Based Incentive Payment System (MIPS) program that is medical toxicology specific.
- Demonstrate the value of toxicological care.
- Facilitate appropriate toxicological care research.
- Provide a unified method for ACMT members to collect and submit MIPS data, and other related or applicable quality and patient safety data to meet quality improvement and regulatory requirements.
- Chance to contribute to an important multicenter research program that is attempting to generate useful practice analytics
Can Medical Toxicologists Use the TQCDR to Meet MIPS Participation Requirements?
Yes. Medical Toxicologists may use the TQCDR to meet MIPS participation requirements. A Qualified Clinical Data Registry (QCDR) is one of several available reporting mechanisms for satisfactory MIPS participation in 2018. If you decide to use the TQCDR for MIPS participation, ACMT will submit your quality measures and improvement activities to CMS on behalf of your physicians and/or group practices. By using the TQCDR to participate in the MIPS program, medical toxicologists may be able to avoid a negative payment adjustment for not reporting, and potentially earn an incentive. For those medical toxicologists who are interested, ACMT will submit physician and/or group practice quality measure data to CMS on an annual basis.
Can I Still Participate in the TQCDR Even If I Don’t Need to Submit Data to MIPS Through the TQCDR?
Yes. While we recognize that some medical toxicologists already report to MIPS through their emergency medicine practice, we strongly encourage all medical toxicologists who care for patients at the bedside and/or in the clinic setting to participate in the TQCDR regardless of whether you need to participate in the TQCDR to meet the MIPS requirements. This is the opportunity for medical toxicologists to develop a data stream to CMS that will improve quality care, and to be recognized. By participating in the TQCDR your data will greatly enhance national quality improvement efforts, help develop benchmarks for medical toxicology practice, and further critically important medical toxicology research efforts.
Is there a minimal number of participants needed to maintain a QCDR?
Yes. ACMT must have at least 25 participants to maintain the ToxIC QCDR. These participants do not need to use the QCDR to report MIPS data to CMS, but they must submit data to the QCDR for quality improvement.
Do I have to be a member of ToxIC to participate in the TQDR?
Yes. We actively encourage ACMT members who care for patients at the bedside and/or in the clinic to participate in the ToxIC Core Registry. Participation in ToxIC will provide a seamless mechanism to activiely participate in the ToxIC QCDR.
Is there a minimum number of cases that need to be reported to the TQCDR?
Yes. According to the CMS regulations, for those who wish to report to CMS to fulfill MIPS requirements one must report on a minimum of 20 records for at least 6 measures. For each measure one should enter at least 60% of their cases that meet that measures denominator. To meet the 20 record threshold per measure one can report either as in individual or a group.
What is a Quality Measure?
Quality measures are tools that help us measure or quantify healthcare processes, outcomes, patient perceptions, and organizational structure and/or systems that are associated with the ability to provide high-quality health care and/or that relate to one or more quality goals for health care. These goals include: effective, safe, efficient, patient-centered, equitable, and timely care.
What is a Process Quality Measure?
Process measures indicate what a provider does to maintain or improve health, either for healthy people or for those diagnosed with a health care condition. These measures typically reflect generally accepted recommendations for clinical practice. Process measures can inform consumers about medical care they may expect to receive for a given condition or disease, and can contribute toward improving health incomes. The majority of health care quality measures used for public reporting are process measures. As presently configured the TQCDR consists of process measures only. In the future we hope to develop medical toxicology outcome measures to add to the QCDR
What is a MIPS measure?
MIPS measures are a series of core measures that have been developed over the last few years under the guidance of CMS. Costs to develop the MIPS measures typically exceeds $100,000 per measure. Many are not specialty specific. The only current MIPS measures that have applicability to medical toxicology are measures on medication documentation, smoking cessation and screening for unhealthy alcohol use.
What are the 4 MIPS measures that will be available for reporting using the TQCDR?
- Documentation of Current Medications in the Medical Record
- Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention
- Tobacco Use and Help with Quitting Among Adolescents
- Preventive Care and Screening: Unhealthy Alcohol Use: Screening & Brief Counseling
What is a non-MIPS QCDR measure?
A “non-MIPS” measures approved by CMS for reporting are often more relevant to the eligible clinician’s specialty care. These measures are clinician initiated. ACMT decided to develop its own QCDR in order to provide the opportunity to report on specific medical toxicology measures that would be more applicable to medical toxicology practice.
What are the 6 non-MIPS QCDR measures that will be available for reporting using the TQCDR?
- Appropriate treatment for acetaminophen ingestions
- Repeat assessment of salicylate concentrations in overdose patients
- Assessment of suspected ethylene glycol or methanol exposures
- Screening for risk of opioid misuse/overuse
- Pregnancy test in women who receive a toxicologic consult
- EKG assessment in acute overdoses
How were these 6 non-MIPS Medical Toxicology Specific measures developed?
In 2015 ACMT convened a workgroup to develop measures that would be medical toxicology specific. A consultant was hired to assist in the measure development. A number of ACMT volunteers worked on developing 15 unique measures. A consensus was developed on each of the measures and the entire measure list was then sent to the ACMT membership for critical review. Reviewer comments were then adjudicated and a final measure list was submitted to CMS. In December 2017 CMS approved 6 of these measures for inclusion in the TQCDR.
What measures are available for reporting by medical toxicologists?
Medical Toxicologists are allowed to report a combination of MIPS and non-MIPS measures for successful MIPS participation.
What happens if I don’t agree with the specific measure?
That is ok. We are trying to understand how medical toxicologists currently practice. Generating data about practice will be critically important as we add to the knowledge base of medical toxicology practice. Given the drive to establish value based health care delivery for medical toxicologists, we believed we need to start someplace and that this pilot effort will build upon a base to continue to revise and better justify these measures.
Does the Measure suggest a stand of care and/or is it a clinical guideline?
No. This Measure is not a clinical guideline and does not establish a standard of medical care, and has not been tested for all potential applications.
Is it expected that all medical toxicologists will practice to the specifics of the measure?
No. In fact if all medical toxicologists performed well on the measure CMS will NOT approve the measure. CMS is looking to medical societies such as ACMT to develop measures where there is a practice gap (not all specialists perform equally well on the measure). In fact if 50% of those who report perform on that measure 95% or greater than the measure will be considered “topped-off” and the measure will be eliminated in subsequent iterations of the QCDR. CMS has requested that ACMT summarize their 2018 Q1 and Q2 data to assess whether the medical toxicology measure have a high-performance rate. Measures with a high-performance rate will be eliminated from the QCDR.
Development of Benchmarks for Medical Toxicologists
The ACMT ToxIC QCDR (TQCDR) leads the effort in developing benchmarks and comparisons to help medical toxicologists improve quality of patient care with its range of medical toxicology measures. TQCDR participants receive access to accurate and objective measures regarding the quality of medical toxicology process measures in comparison to other medical toxicologists nationwide.
Is ACMT Planning to Develop Additional Medical Toxicology Measures?
Yes. This initiative is just a start. Over the next 1-2 years we will need to develop additional measures including outcome measures.
Who can report?
Medical Toxicologists can report to the TQCDR as individuals or as a group. The TQCDR supports both individual clinicians and physician group practices in meeting MIPS requirements.
- Supports both individual medical toxicologists and medical toxicologist group practices in meeting MIPS requirements
- ACMT QCDR non - MIPS measures are developed by ACMT and may be more meaningful and applicable to the care medical toxicologists provide
- Provides direct assistance with compiling the needed data for quality improvement
- Provides feedback to registry participants at least quarterly and on - demand via the MIPS portal
- Allows physicians to review and select measures to report prior to CMS submission deadline