In March 2017, Executive Director Laurie Kendall-Ellis represented the Alliance in the MACRA Working Group as it met with Pierre Yong, MD, and other leaders from CMS’s Division of Quality Measurement to promote the value of PI CME activities in the MIPS enacted as part of the MACRA law.
Making the Case
The working group, which also included Amy Smith (AAFP), Norm Kahn (CMSS), Todd Dorman (SACME), Tom Sullivan (Rockpointe/CME Coalition) and Andrew Rosenberg (CME Coalition), fielded questions from Young and colleagues and provided case study examples supporting the applicability of this type of CME into MIPS. The group explained how PI CME is different from other types of CME, outlined its availability across the CME enterprise, and answered process-related questions about how such CME is funded, accredited, and aligned with state licensure and MOC requirements.
When asked whether the group suggested that there be a separate "category" for MIPS-creditable PI CME, Amy Smith noted that the AAFP has the infrastructure in place to support this and would be happy to accommodate such an approach, as it seems similar to ACCME's AAIA proposal.
The CMS expressed the concern that MIPS credit should not be provided for activities that physicians should be doing already as part of their standard practice (e.g., writing a complete note in a patient's worksheet). The MACRA Working Group agreed, pointing out that it could further spell out the proposed definition of MIPS-worthy PI CME to emphasize that the activity must address an existing, documented quality or safety gap.
Promoting a Shared Vision
Importantly, the working group emphasized that the key represented organizations (CMSS, AAFP, Alliance and SACME) all agreed with the ACCME on the approach for incorporating PI CME into MIPS, which included the following recommendations:
- The educational activity should address a quality or safety gap that is supported by a needs assessment or problem analysis or must support the completion of such a needs assessment as part of the activity.
- The activity should have specific, measurable aim(s) for improvement.
- The activity should include interventions intended to result in improvement.
- The activity should include data collection and analysis of performance data to assess the impact of the interventions.
- The accredited CME provider must define meaningful physician participation in their activity, describe the mechanism for identifying physicians who meet the requirements and provide participant completion information.
The group also emphasized that the AAFP sees CME as an important and trusted vehicle by which all physicians — including those in small, rural practices — can access opportunities that meet CMS requirements and that CME is strongly and fundamentally shifting its focus to professional development.
Taking Next Steps
At the CMS’s request, the MACRA Working Group will be providing evidence (i.e., outcome reports) on the effects of PI CME on clinicians.