CMS Seeking Practices to Test “Closing the Referral Loop” Measure
The American Academy of Family Physicians was recently made aware that state chapters received a letter from Shari Glickman of Mathematica, a Centers for Medicare and Medicaid Services (CMS) contractor, requesting they share an opportunity for primary care practices to participate in testing a potential electronic clinical quality measure (eCQM), “Closing the Referral Loop: Receipt of Specialist Report.” Practices are being offered an honorarium of $2,000 to $4,000 for testing.
The AAFP recognizes the importance of this topic to primary care, and agrees there are serious gaps in the referral process. We are not discouraging interested practices from participating in the testing. However, we do want you to be aware of the concerns we expressed to the developers of a similar registry-based measure last fall—concerns that also hold true for this eCQM. These concerns should be closely considered by practices during testing to determine their impact on performance score. Practices which participate should be encouraged to express concerns to Mathematica during testing.
- The provider (i.e., the family physician) who refers the patient to another provider is being held accountable for the performance of this measure. In other words, the family physician is being held accountable for the specialist having timely available appointments, scheduling and seeing the patient, and promptly delivering a report back to the primary care physician (PCP). The AAFP opposes family physicians being held accountable or penalized if a specialist does not complete their professional responsibilities, or if specialty services are not readily available in a geographic area. In addition, while medical homes have agreed to do referral tracking, the process is extremely time-consuming and expensive. The referral tracking function is not user-friendly in many EHRs. The measure may be more tenable for APMs or health systems that refer predominantly to in-network providers who share responsibility for performance.
- The time frame of the measure is not feasible (i.e., all patients seen from January 1 – December 31), since patients seen late in the year may not have an opportunity to be scheduled and seen by a specialist, and generate and return a report to the PCP prior to the end of the year. Geographic area and availability of specialists impacts the ability to complete a referral. Rural providers in particular may be at a disadvantage related to specialist availability. The measure may have an unintended consequence of discouraging referrals that are necessary.
- The measure looks only at ONE referral per patient per year, so will not provide an accurate, comprehensive rate for all referrals, particularly for complex patients with multiple chronic or acute conditions that may have multiple referrals.
- It is not clear how telehealth visits with specialists are handled in this measure.
- There should be an exclusion for patients that are referred, but do not follow-through, or for patients that cancel their appointment.
Contact Sandy Pogones or call 800.274.2237, ext. 4174 with questions.