The Centers for Medicare & Medicaid Services (CMS) and its contractor, Acumen, LLC, will conduct field testing for 5 newly developed episode-based cost measures, including a Low Back Pain (LBP) cost measure, from January 10 through February 25, 2022.
Update: Deadline extended through March 25, 2022.
The LBP measure was developed with input from various specialty societies, including AAPM&R. The cost measure workgroup included representation of two physiatrists, Dr. Andrew Gordon and Dr. Carlo Milani. The measure focuses on chronic/medical management of low back pain whereas a previously developed Lumbar Spine Fusion cost measure, which is currently in use under the Merit-based Incentive Payment System (MIPS), focuses on acute management of surgical patients. Under the attribution methodology, for the new LBP measure, Physical Medicine and Rehabilitation is called out as the specialty with the third most attributed episodes, behind Chiropractice and Physical Therapy.
Download a sample Low Back Pain Cost Measure Field Test Report.
The LBP measure will undergo field testing before it is considered for use in MIPS and tied to performance-based Medicare payment adjustments. Field testing is an opportunity for clinicians to learn about episode-based cost measures and to provide feedback via an online survey on the draft measures. It also helps Acumen assess each measures' importance, scientific acceptability, and clincial validity. Feedback shared on the LBP measure will be used to consider potential measure of refinements following field testing.
Clinicians and clinician groups attributed at least 20 episodes for the LBP measure are able to access a Field Test Report with information about their cost performance that covers the period from January 1 to December 31, 2019. The start or continuation of a clinician or group’s management of a patient’s low back pain is identified by the appearance of Medicare claims for a pair of services within 60 days of one another. Certain E&M and procedural codes (e.g., spinal injections, spinal neurostimulators, and imaging) coupled with a relevant ICD-10 diagnostic code for LBP would trigger the episode. The measure is stratified into smaller patient cohorts that recognize the need to consider surgical patients and non-surgical patients separately and complex LBP patients (i.e., radiculopathy, spinal stenosis, or spondylolisthesis) and non-complex LBP patients separately.
For a more detailed description of the measure’s population, subgroups, and attribution methodology, please see the low back pain files in this Measure Specifications zip folder. The folder includes an Excel file a list of the codes that specify the measure as well as the measure’s full specifications (appendix document) and methods for development of the measure.
How to Provide Feedback
All stakeholders—regardless of whether you receive a report—are invited to provide feedback. You can provide feedback on the draft measure specifications through this online survey. A document containing specific questions about the measure for stakeholders to reference while reviewing the materials is available here.
- The survey will open on January 10 and close at 11:59 pm (ET) on February 25.
- All survey questions will be optional. Participation is voluntary, and all feedback may be submitted anonymously.
- You may attach a comment letter (as a PDF or Word document) in addition to or as an alternative to responding to the survey questions.
- The link to the survey, which does not require a login, will be included in the Field Test Reports and across other supplemental documentation so that you will be able to navigate easily to it from the documents you review.
Stakeholder feedback is vital in the measure development process and will inform the final specifications of the LBP episode-based cost measures currently under development. AAPM&R is in the process of developing comments. We hope you will consider sharing your input.
Field Testing Materials
Field testing materials will be available on the MACRA Feedback Page and at the links below at the start of field testing, including:
- Specifications for the measures undergoing field testing
- Informational field testing documents
- Documents about accessing the Field Test Reports
Cost Measures Field Testing Webinars
Stakeholders may also access a recorded field testing webinar (slides and recording) that provides information on the cost measures undergoing field testing.
Accessing the Field Test Reports
You or your group’s authorized representative can access the Measure Field Test Report(s) at https://qpp.cms.gov/login using a Quality Payment Program website account. If you do not have an account, you will need to register for a HCQIS Access Roles and Profile (HARP) account in order to sign in.1 Once you have access, you can connect with your organization by navigating to the “Manage Access” tab of the Quality Payment Program website. If you’re part of a clinician group, you’ll select the “practice” organization type, and if you’re an individual clinician, you’ll select the “individual clinician” organization type.
The Quality Payment Program Access User Guide (download here) provides more information on how to sign up for a Quality Payment Program account and how to connect with the appropriate organization.2
Note: Field Test Reports are separate from the Quality Payment Program Performance Feedback Reports, though both reports are made available through this website.
Groups are identified by their Medicare billing TIN. A group consists of two or more eligible clinicians, as identified by their NPIs that bill under the same TIN. A group will receive a Field Test Report if the TIN is attributed the minimum number of cases for a measure among all NPIs billing under the TIN. For a QPP account, a group can have either of the following roles:
- Security Official
- Staff User
Users who have a Security Official role will be able to see all TIN- NPI reports within their TIN, as well as the TIN’s overall report, so it’s a role that is more appropriate for someone who is in an administrative position at the TIN. Each organization must have a Security Official role before any other group members can request a Staff User role. The group-level users (i.e., Security Official and Staff Users) have access to the group practice’s reports and the individual-level reports for the solo practitioners within the group practice.
An individual eligible clinician (or a solo practitioner) is identified by a single NPI that bills under the TIN. They’ll receive a Field Test Report if the NPI is attributed the minimum number of cases for a measure. Clinicians looking to view only their TIN-NPI report should connect to the individual clinician organization type, regardless of whether they’re a part of a group practice or they practice on their own. The Field Test Report Access User Guide available on the MACRA Feedback Page at the start of field testing provides more information on accessing a Field Test Report.
To learn more about the episode-based cost measure development process, please refer to the Measure Development Process document.
The LBP measure represents Wave 4 of CMS/Acumen’s episode-based cost measure development. This process began in December 2020 and is scheduled to conclude in May 2022. The workgroups providing input on the five Wave 4 measures undergoing field testing in 2022 represent a total of 86 members affiliated with 66 professional societies, including AAPM&R. Summaries from workgroup meetings held to-date can be found on the MACRA Feedback Page.
If you have specific questions about the LBP measure or how to access your field test report, please contact the AAPM&R Health Policy Department at email@example.com
1 CMS, “QPP Account,” Quality Payment Program, https://qpp.cms.gov/login?page=register
2 CMS, “Quality Payment Program Access User Guide,” Quality Payment Program, https://qpp-cm-prod-content.s3.amazonaws.com/uploads/335/QPP%20Access%20User%20Guide.zip