PQRS: Are you satisfactorily reporting?

As you may already be aware, CMS has many quality initiatives. One of which is the Physician Quality Reporting System (PQRS).  For those of you who do not already participate, PQRS began in 2007 as an incentive based reporting program for eligible providers to report quality data to the Centers for Medicare & Medicaid. The data collected was based off of “quality measures,” which are indicators that help CMS quantify the quality of care provided by physicians.  While physicians could receive incentive payments for participating in prior years, physicians are now subject to a penalty, or “payment adjustment,” if they fail to successfully report.

Why participate?

  1. Avoid negative payment adjustments. By becoming a “satisfactory reporter” for 2015, you can avoid 2017 PQRS negative payment adjustments.
  2. Avoid Value Based Modifier payment adjustments. The Value Based Modifier, a separate program from PQRS, hinges on PQRS reporting, but is based upon the quality of care furnished compared to the cost of care during a performance period. If you successfully report PQRS in 2015, you can avoid the 2017 VM payment adjustment. (Note: The VM payment adjustment is in addition to the negative PQRS payment adjustment. If you fail to successfully report PQRS in 2015, you will get a negative 2% payment adjustment for PQRS and a negative 2% payment adjustment for VM, resulting in a total negative 4% payment adjustment).
  3. Help to drive the quality of health care. By participating you are helping to provide CMS with ways to quantify and thus help to improve the quality of health care.

How do I report PQRS measures?

Before you decide how you want to report your PQRS measures, you must decide if you want to submit your measures as an individual Eligible Provider (EP) or, if you are a group of 2+, if you want to submit your measures as a PQRS Group Practice. PQRS defines a group practice as a single TIN with 2 or more individual EPs (as identified by Individual National Provider Identifier (NPI)) that have reassigned their billing rights to the TIN. In order to report as a group practice, your group must register for the Group Practice Report Option (GPRO) (The deadline for registering as a group practice for 2015 was June 30, 2015).

It should be noted, that reporting requirements differ depending on the way in which an EP or PQRS group practice decides to report.

Reporting Options 
Individual Eligible ProvidersPQRS Group Practices (options for 2-24 physician practices)
Medicare Part B claims submission**N/A
Reporting electronically using an EHR that is Certified Electronic Health Record Technology (CEHRT)Reporting electronically using an EHR that is Certified Electronic Health Record Technology (CEHRT)*
EHR data submission vendor (DSV) that is CEHRTEHR data submission vendor (DSV) that is CEHRT
Qualified PQRS Registry**Qualified PQRS Registry**
Qualified Clinical Data RegistryN/A

 

*Contact your EHR vendor to see if their product is CEHRT.

**From ENT Billings research, these reporting methods appear to be the easiest.

 

How do I report PQRS measures if I am part of an Accountable Care Organization (ACO)?

If you are part of an Accountable Care Organization (ACO), the ACO is typically in charge of reporting for PQRS. However, there are a few different types of ACOs so you may want to contact the head of your ACO or refer to your contract to make sure measures are being reported.

So you mentioned, Claims based or Registry Reporting is easiest. Tell me how to report.

How do I report via Claims based reporting?

Claims based reporting is only an option for individual EP’s and is not an option for PQRS group practices. Medicare providers simply submit claims containing the PQRS QDC lines via the CMS-1500 form. Quality measures data reported on claims denied for payment are not included in PQRS analysis. QDC line items are then reviewed to make sure they met measure specifications (i.e. coding instructions, reporting frequency, and performance timeframes).

To meet claims reporting criteria:

  • Physicians must report on at least NINE measures across three National Quality Strategy Domains for 50% of your Medicare Part B Fee-for-Service (FFS) patients for the year.
  • You must report on at least one “cross-cutting” measure, which are non-specialty specific measures (this can count as one of your nine measures).
  • Measures with a 0% performance rate will not be counted

How do I report using a Qualified Registry?

EPs and PQRS group practices may report using a qualified registry to avoid the PQRS negative payment adjustments. A qualified registry is a medical registry (or a maintenance of certification program) who performs the collection and submission of PQRS data on behalf of EPs and/or group practices. To select a qualified registry vendor, refer to the 2015 Participating Registry Vendors list which will be posted by CMS by May 30, 2015.

Reporting Criteria for Individual EPs:

  • CHOICE ONE:
  • Physicians must report on at least NINE measures across three National Quality Strategy Domains for at least 50% of the Eps Medicare Part B fee-for-service patients.
  • You must report on at least one “cross-cutting” measure, which are non-specialty specific measures (this can count as one of your nine measures).
  • Measures with a 0% performance rate will not be counted
  • CHOICE TWO:
  • Report at least 1 measures group on a 20-patient sample, a majority of which much be Medicare Part B Fee-for-Service patients (i.e. at least 11 out of 20). Refer to “PQRS Group Measures Manual” for additional details.
  • Suggested group measures applicable to ENT:
    • Sinusitis Measures Group (pg 367 in Measures Group Manual
    • Acute Otitis Externa (AOE) Measures Group (pg 383 in Measures Group Manual)

Reporting Criteria for Group Practices:

A group practice must have registered to report via qualified registry under the GPRO for 2015 PQRS.

  1. Report on at least NINE measures across three National Quality Strategy Domains for at least 50% of the Eps Medicare Part B fee-for-service patients.
  2. You must report on at least one “cross-cutting” measure, which are non-specialty specific measures (this can count as one of your nine measures).
  3. Measures with 0% performance rate will not be counted.

Other things to note:

Participating Registry’s usually charge around $199 per provider to report PQRS data.