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Malnutrition MIPS Improvement Activity Included in QPP Proposed Rule

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In the recently released Centers for Medicare & Medicaid Services (CMS) proposed rule for the CY 2022 Medicare Physician Fee Schedule, CMS proposed to include an Avalere-submitted malnutrition-focused improvement activity (IA) in the Merit-based Incentive Payment System (MIPS).

If included in the final Medicare Physician Fee Schedule, the IA, which the CMS slightly modified to title “Implement Food Insecurity and Nutrition Risk Identification and Treatment Protocols,” would be an approved activity for provider scoring in the IA performance category. This category represents 15% of a reporting clinician’s or clinical practice’s total MIPS composite score and has implications for value-based payment. If finalized, the inclusion of this IA would represent the first nutrition-related improvement activity of its kind supporting comprehensive nutrition risk and food insecurity risk identification and treatment.

New MIPS Improvement Activity Focused on Malnutrition and Food Insecurity

Avalere developed this proposed IA in partnership with the Academy of Nutrition and Dietetics based on quality improvement resources and measures developed as part of the Malnutrition Quality Improvement Initiative (MQii). Based on the growing body of evidence for the importance of improving health through appropriate and high-quality nutrition care, the MQii is designed to bring about better care quality and health outcomes for older adults who are malnourished or at risk of malnutrition. The MQii provides a set of free, web-based resources—including a toolkit and a set of electronic clinical quality measures—to support quality improvement centered on optimal nutrition care for those at highest risk of malnutrition.

The CMS has focused many of its proposed changes this year on advancing value-based care and addressing health equity and social determinants of health, including proposing 7 new IAs (of which the malnutrition/food insecurity IA is 1). Proposed IAs are available for comment through September 13, 2021.

Various Opportunities for Eligible Clinicians to Receive MIPS Credit

Multiple actions can be implemented to receive credit for this IA. They include using quality improvement resources (including those offered by the MQii) to improve screening and subsequent interventions, electronic health record-based clinical decision support tools, staff training, and referrals to and engagements with community-based organizations to meet the needs of patients who screen positively for food insecurity or malnutrition. Such programs might involve helping patients to enroll in a federal nutrition program, providing a healthy food prescription to help pay for healthy groceries, or delivering medically tailored meals, among other interventions.

Multiple types of providers can currently attest to IAs, including physicians, dietitians, and other clinicians. Beginning in the 2023 performance year, the CMS proposes including clinical social workers and certified nurse-midwives to better meet needs across patient populations.

Any trained clinician is able to screen for malnutrition and food insecurity.

Reinforcing the Focus on Health Equity

By including this IA in its proposed rule along with other changes to the QPP (Quality Payment Program), the CMS recognizes that effectively addressing health disparities—including through appropriately identifying and treating patients who are more likely to be malnourished or food insecure—can lead to improved health outcomes, reduce unnecessary healthcare utilization, and advance health equity. If included in the final rule, this MIPS IA would be the first that explicitly allows providers to attest to quality improvement efforts focused on food insecurity and malnutrition care. Appearing under the category of “Achieving Health Equity,” it may also incentivize clinicians to focus on meeting the nutritional needs of particularly vulnerable patients, which may be more comprehensive given that historically marginalized communities have been shown to be more likely to have poor access to nutritious food and suffer from chronic conditions. Such stark differences in nutrition-related health outcomes across demographic groups have been reported in the 2018 national claims analysis published by the Healthcare Cost and Utilization Project. In this analysis, malnutrition diagnosis codes were 23% higher in claims for hospitalized Black Americans than for the general population. These disparities present an opportunity for targeted and comprehensive interventions, programs, and policies that specifically address these long-standing differences in outcomes among populations.

Increased Opportunities to Improve Quality of Nutrition Care

This step by the CMS and the Biden administration represents a move toward addressing health equity and social determinants of health (SDOH), and it provides another opportunity for providers to adopt incentives to address malnutrition and food insecurity, which play prominent roles in disparate health outcomes.

In addition to the proposed inclusion of this IA, Avalere developed the Global Malnutrition Composite Score that recently received endorsement by the National Quality Forum (pending completion of the Consensus Standards Approval Committee appeal period). Clinicians and administrators can use this measure to further track and manage the quality of nutrition care being delivered to patients. Learn more about this new quality measure by reading our previous insight and the journal article on its development and use in a national hospital learning collaborative.

As the CMS begins to align and focus its priorities for its quality and value-based programs on health equity and SDOH, nutrition care is positioned to play a more prominent role. This is especially important given the benefits of improved nutrition to patients across care settings. Healthcare stakeholders have an opportunity to partner with providers in myriad ways to ensure patients receive high-quality nutrition care. MIPS credit may provide an incentive to participating providers to deliver care that is comprehensive and patient centered.

Support for the MQii is provided by Abbott.

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