One point of interest for all physicians related to the release of the Medicare Physician Fee Schedule each year, including Emergency Physicians, 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. Available reporting mechanisms include 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 is 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.
- Four common PQRS Measure reported by emergency medicine providers are no longer available: Measure 28: Aspirin at Arrival for Acute Myocardial Infarction (AMI); Measure 55: Emergency Medicine: 12-Lead Electrocardiogram (ECG) Performed for Syncope; Measure 56: Emergency Medicine: Community Acquired Bacterial Pneumonia (CAP): Vital Signs; Measure 59: Emergency Medicine: Community Acquired Bacterial Pneumonia (CAP): Empiric Antibiotic;
- Two proposed measures that would have applied to emergency medicine providers—Avoidance of inappropriate use of imaging for adult ED patients with traumatic low back pain AND Median Time to Pain Management for Long Bone Fracture—were not finalized.
As the requirements for the PQRS program become more stringent, and particularly, as claims-based measures related to emergency medicine continue to diminish, more providers may be interested in participating in PQRS through a registry.
The American College of Emergency Physicians (ACEP) has negotiated with CE City, a leading registry vendor, to provide a discount to ACEP, Emergency Medicine Residents’ Association (EMRA), and Society of Emergency Medicine Physician Assistants (SEMPA) members. Individual providers or groups of up to nine providers who are ACEP, EMRA, or SEMPA members can receive $100 off the $299 per provider fee. ACEP has negotiated a deeper discount of 10% off ($179) for groups of 10 or more and 15% ($169) for groups of 20 or more. ACEP members can visit acep.pqrswizard.com to take advantage of this member benefit.
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 ACEP’s registry offer, visit their quality registry webpage.
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