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Understanding the APMA Registry

Thursday, September 21, 2017  
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As I have noted in previous columns, APMA is building its own registry. The APMA Registry has been approved by CMS as a Qualified Clinical Data Registry (QCDR) for 2017. But what exactly does that mean and as an APMA member how can I utilize the APMA Registry?
As a QCDR, the APMA Registry will have the capability of submitting the components of the Merit-Based Incentive Payment System (MIPS). The three components of MIPS for the 2017 performance year are Quality (essentially submitting quality measures very similar to what existed in PQRS), Advancing Care Information (ACI—which retains many of the components of what was formerly Meaningful Use (MU)), and Clinical Practice Improvement Activities (or Improvement Activities—a new category of activities). The components of MIPS and how to participate to achieve the maximum score (or how to just avoid the penalty) have been covered in detail previously and can be found here.

So how, as an APMA member, do I utilize the APMA Registry to submit the required  components of MIPS? First, you need to sign up for the APMA Registry. It is fairly quick and  easy, but you should be prepared with your individual (not group) National Provider Identifier (NPI) number and Tax ID Number (TIN) and you should know if you want to report for MIPS as an individual or as a group (more information on individual or group reporting can be found here) For group submission through the APMA Registry, each member of your group should sign up with their individual NPI and the TIN that the group bills under. The Quality Payment Program for Medicare does not utilize a group NPI number. As each member of the group signs up, they should indicate that they are going to do group reporting. You can also check your participation status for MIPS utilizing your NPI number (remember you must meet the qualifications for each NPI/TIN that you bill under). Once you have all the information, you can go to the APMA Registry to sign up. Visiting the website and completing the APMA Registry Access Request Form is the first step in the registration process. You will then be contacted to complete a Business Associate/Data Use Agreement that meets the HIPAA requirements for submission of data to the registry—APMA is developing this agreement and it should be available in the near future--after doing the initial registration you will be contacted when this document is available for completion.

You have signed up on the website, completed your BAA/Data Use Agreement—now what? The next steps will depend on several factors. First, you will have to decide which components of MIPS you plan to report for the 2017 performance year. The ACI and Improvement Activities are reported by attestation, so all APMA members who complete their registration (including        the BAA/DUA) with the APMA Registry will be able to attest to these components through the registry. Attestation will occur between January 2 and March 31, 2018. APMA will send out information to all members who complete their registration with the specific details on how to do the attestation for these two MIPS components.

The remaining component of MIPS is Quality. To utilize the APMA Registry to submit the Quality component of MIPS, your electronic health record vendor will need to have completed integration with the APMA Registry. Although APMA has reached out to many vendors, for 2017 there will probably be very few vendors that complete the integration. APMA will keep the membership updated on vendors as they integrate, but unless your vendor assures you  they will complete the integration, you should probably plan to submit the Quality component for the 2017 performance year with a different registry or by a different method (i.e. claims). Also, if your vendor integrates you will have to select from the 11 measures that the APMA Registry has indicated to CMS that they will report as a QCDR (list available here).

The bottom line is that the APMA Registry will be available for submission of at least some MIPS components for all APMA members participating in MIPS for the 2017 performance year. APMA will continue to expand the registry capabilities and functions in 2018 and beyond to serve the needs of members.