One point of interest for all physicians related to the release of the Medicare Physician Fee Schedule each year is the updated Physician Quality Reporting System (PQRS) guidelines, especially since 2013 when the program began penalizing unsuccessful reporters.
While Medicare updates their PQRS educational materials with specific guidelines, there are a few things to know about the 2015 program.
- Successful PQRS submission for 2015 will allow eligible providers to avoid a 2 percent payment adjustment in 2017. Incentive payments are no longer available for PQRS.
- Beginning in 2015, eligible professionals in Critical Access Hospital billing under Method-II (CAH-IIs) may participate in the PQRS using ALL reporting mechanisms available, including the claims-based reporting mechanism.
- All reporting mechanisms used in 2014 are still available in 2015, though the number of claims-based measures continues to dwindle: claims; qualified registry; EHR (including direct EHR products and EHR data submission vendor products); the Group Practice Reporting Option (GPRO) web interface; certified survey vendors, for the Consumer Assessment of Healthcare Providers and Systems (CAHPS) for PQRS survey measures; and the Qualified Clinical Data Registry (QCDR).
- For the 12-month reporting period for the 2017 PQRS payment adjustment, eligible professionals generally have to report on 9 measures across 3 National Quality Strategy (NQS) domains for at least 50 percent of the Medicare patients seen. If fewer than 9 measures apply, then professionals should report 1-8 measures, and the Measure Applicability Validation (MAV) will be applied. As in previous years, MAV evaluates if any additional measures should have been reported based on clinically related clusters, and if so, if there were more than 15 patients in the denominator of those additional measures, then the provider should have reported PQRS and will be subject to the 2 percent payment adjustment.
- For the claims and registry reporting mechanisms, if an individual provider (or a group in the case of GPRO registry) sees at least one Medicare patient in a face to face encounter in 2015, then one of their required 9 PQRS measures submitted must be chosen from a list of 18 newly categorized cross-cutting measures.
- The sample size for submission for groups electing the GPRO web interface mechanism in now 248, regardless of the number of eligible providers in the group.
- Groups of 100 or more eligible professionals utilizing any of the GPRO reporting options must have all CAHPS for PQRS survey measures reported on their behalf via a CMS-certified survey vendor. CAHPS for PQRS is optional for groups of 2-99 eligible professionals.
- A common PQRS Measure reported by anesthesiologists—Measure 30: Perioperative Care: Timing of Prophylactic Antibiotic by Administering Physician—is no longer available.
As the requirements for the PQRS program become more stringent, and particularly, as claims-based measures related to anesthesia continue to diminish, more providers may be interested in participating in PQRS through the Anesthesia Quality Institute’s (AQI) Qualified Clinical Data Registry.
According to AQI, requirements for individual eligible providers for their program are as follows:
- Be a member of ASA or purchase reporting through ASA.
- Be a National Anesthesia Clinical Outcomes Registry (NACOR) participant. Steps include: 1.) completion of a Business Associate Agreement with the AQI, 2.) payment of any necessary fees. AQI participation is free to ASA members and any EPs working with them in the care team model, 3.) completion of the AQI practice profile, including the national provider identifiers of all EPs in the group, and 4.) transmission of electronic data to the registry (including the necessary measure codes) beginning in January 2015.
- Self-nominate with AQI for QCDR reporting at the beginning of 2015.
- Work with AQI for QCDR reporting at the beginning of 2015.
- Attend regular phone calls/meetings to ensure that AQI is receiving the proper data.
- Sign off on the regular monthly data reports that AQI will send to the practice.
- Approve the final transmission of EP performance data to CMS.
CIPROMS will continue to update our own educational materials and provide additional articles and guidance on PQRS as CMS releases more detailed information.
For more information about PQRS, visit the CMS PQRS webpage or review the 2015 Medicare Physician Fee Schedule Final Rule with Comment Period. For more information about AQI’s QCDR, visit their PQRS in 2015 webpage.
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