Now is the time to begin considering your options for the 2015 reporting year of the Medicare Physician Quality Reporting System (PQRS), particularly if you are planning to participate as an individual reporter through claims submission. For the 2015 reporting year, there are no further payment incentives. Instead, successfully reporting PQRS for 2015 will allow you and your group to avoid a 2 percent payment adjustment in 2017.
Step 1: Determine whether you will participate as individual providers or as a group with other members of your practice (grouped by Tax ID Number [TIN]). (Remember, to avoid the automatic value-based payment modifier (VBPM) payment adjustment for 2017, your group must avoid the 2017 PQRS payment adjustment as a group or 50 percent or more of the individual providers in your group must avoid the 2017 PQRS payment adjustment as individuals.)
Step 2: As you are determining whether you will participate as a group or individual, remember the following submission options are available for each.
Individual:
- Claims
- Qualified Registry (requires choosing a registry vendor to submit on your behalf, usually at a cost per provider)
- EHR (EHR product must be certified for the PQRS program)
- Qualified Clinical Data Registry (requires choosing a clinical data registry vendor to submit on your behalf, usually at a cost per provider)
Group (GPRO):
- Qualified Registry (requires choosing a registry vendor to submit on your behalf, usually at a cost per provider)
- Qualified Registry plus CMS Certified Survey Vendor (requires choosing a registry vendor to submit on your behalf, usually at a cost per provider)
- EHR (EHR product must be certified for the PQRS program)
- EHR plus CMS Certified Survey Vendor (EHR product must be certified for the PQRS program)
- Web Interface
- Web Interface plus CMS Certified Survey Vendor
Step 3: Keep in mind a few special guidelines by reporting method.
- Generally, for all reporting options except web interface, to avoid the 2 percent payment adjustment in 2017, individual or group providers will need to report on 9 or more quality measures covering 3 or more National Quality Strategy Domains (NQSD).
- If a group or individual reporting via claims or qualified registry sees at least one Medicare patient in a face-to-face encounter, as least one measure of the required nine must be chosen from a designated list of cross-cutting measures.
- Measures or measures groups reported with a 0 percent performance rate will not be counted for groups or individuals reporting via claims or qualified registry.
- Measures groups are reportable only via registry for individual providers. Providers choosing this option must report at least 1 measures group and report each measures group for at least 20 patients, the majority (11 patients) of which are required to be Medicare Part B FFS patients.
- If an individual is reporting via qualified clinical data registry, then at least 2 of the measures must be outcome measures. If 2 outcome measures are not available, individuals should report on at least 1 outcome measure and at least 1 of the following types of measures – resource use, patient experience of care, efficiency/appropriate use, or patient safety.
- If groups choose to report the CAHPS for PQRS measures with a CMS Certified Survey Vendor in addition to EHR or Qualified Registry, then the number of measures reported via EHR or Qualified Registry drops to 6 over 2 NQSD.
- For groups or individuals choosing the EHR option, if the direct EHR product or EHR data submission vendor product does not contain patient data for at least 9 measures covering at least 3 domains, then the group practice or individual must report the measures for which there is patient data. A group practice must report on at least 1 measure for which there is Medicare patient data.
- Groups choosing the web interface must report all measures included in the web interface and populate data fields for the first 248 consecutively ranked and assigned beneficiaries in the order in which they appear in the group’s sample for each module or preventive care measure. If the pool of eligible assigned beneficiaries is less than 248, then the group practice must report on 100 percent of assigned beneficiaries.
- Groups of 100 or more participating as a group must report the CAHPS for PQRS regardless of which GPRO option they choose.
Step 4: Take the next steps depending on your choices.
- If you are reporting via a qualified registry, qualified clinical data registry, or EHR, begin researching vendors and contacting them for reporting costs and specifications.
- If you are participating in any of the GPRO options, make sure you are registered for the physician value portlet at the CMS.gov Enterprise Portal. For the 2015 reporting year, groups must register for GPRO before June 30, 2015.
- If you are participating via claims as an individual, or via qualified registry, qualified clinical data registry, or EHR as a group, choose your reporting measures for 2015.
To help with choosing measure, the Centers for Medicare and Medicaid Services (CMS) is collaborating with specialty societies to provide suggested Specialty Measure Sets that identify measures associated within a particular clinical area. The Specialty Measure Sets are to be utilized as a guide to assist eligible professionals in choosing measures applicable to their specialty beginning in Program Year 2015. The Specialty Measure Sets are NOT required measures but are suggested measures for a specific specialty. (NOTE: The Specialty Measure Sets represent quality measures contained within the 2014 Physician Quality Reporting System (PQRS) and new measures proposed for 2015 that may be applicable based on a particular clinical specialty.)
- Potential Cardiology Preferred Measure Set
- Potential Emergency Medicine Preferred Measure Set
- Potential Gastroenterology Preferred Measure Set
- Potential General Practice/Family Preferred Measure Set
- Potential Internal Medicine Preferred Measure Set
- Potential Multiple Chronic Conditions Preferred Measure Set
- Potential Obstetrics/Gynecology Preferred Measure Set
- Potential Oncology/Hematology Preferred Measure Set
- Potential Ophthalmology Preferred Measure Set
- Potential Pathology Preferred Measure Set
- Potential Radiology Preferred Measure Set
- Potential Surgery Preferred Measure Set
Complete lists of 2015 measures are available on the CIPROMS website by denominator codes and by reporting option and NQS domain. Check all measures chosen with the specifications outlined by CMS in their official 2015 measures list.
For more information about the 2015 PQRS reporting year for the 2017 payment adjustment, visit CMS’s PQRS webpage. Resources are being updated regularly for the new program year.
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