Reporting PQRS in 2016: What Anesthesiologists Need to Know

As the Centers for Medicare and Medicaid Services (CMS) updates their program descriptions for the 2016 Physician Quality Reporting System (PQRS) reporting year, anesthesiologists have several options for participating, though the reporting option most have used in the past becomes harder than ever to utilize.

In the past, including the 2015 reporting year, most anesthesiologists reported PQRS through the claims option utilizing Measures 44 – Preoperative Beta-Blocker in Patients with Isolated CABG surgery and 193 – Perioperative Temperature Management. With Measure 193 discontinued after 2015 and with Measure 44 modified as registry only beginning in 2016, there are no longer any claims measures with anesthesia codes in the denominator criteria.

So how will anesthesiologists be able to successfully report PQRS for 2016?

1. The claims option is still possible if you perform certain other services in addition to anesthesia procedures and want to participate as an individual in the PQRS program.

The Anesthesia Quality Institute includes the following five measures as potential measures for anesthesiologists in their Qualified Clinical Data Registry (QCDR). These measures also are available in the claims reporting option in the 2016 reporting year:

Measure 76 – Prevention of Catheter-Related Bloodstream Infections (CRBSI): Central Venous Catheter Insertion Protocol
Measure 109 – Osteoarthritis – Function and Pain Assessment
Measure 130 – Documentation of Current Medications in Medical Record
Measure 131 – Pain Assessment and Follow-up
Measure 226 – Preventative Care and Screening Tobacco Use: Screening and Cessation

These codes include CVC placement procedure codes or various evaluation and management services in their denominator criteria. If you perform any of these types of services, you may still be able to participate in PQRS through the claims reporting option.

Under the claims reporting option, you also must report at least 1 cross-cutting measure if you have face-to-face encounters with patients. Review the CMS list of Face-to-Face encounters to see if this applies to you. NOTE: If you are able to report any of the claims measures above, then you will probably have face-to-face encounters. Measures 130, 131, and 226 also are classified as cross-cutting measures.

CMS will analyze claims data to determine if at least 15 cross-cutting measure denominator eligible encounters can be associated with the individual eligible professional. If so and if it is determined that at least 1 cross-cutting measure was not reported, the individual eligible professional with face-to-face encounters will be automatically subject to the 2018 PQRS payment adjustment. For those individual eligible professionals with no face-to-face encounters as found within the 2016 PQRS List of Face-to-Face Encounters, CMS would not require the reporting of a cross-cutting measure.

The measure applicability validation (MAV) process remains in place for the 2016 reporting year for providers who report 1-8 measures across 3 National Quality Strategy (NQS) domains or 9 measures across 1-2 NQS domains in the claims reporting option. MAV will be applied only if all measures that have been reported are reported successfully (regardless of volume) and if providers with face-to-face encounters who are denominator eligible have reported at least 1 cross-cutting measure. (More information about the claims MAV process is available on the CMS website.)

2. The qualified registry reporting option is available to anesthesiologists who participate as individuals or as a group through GPRO.

Unlike the claims reporting option, the qualified registry option offers several measures for anesthesiologists who perform anesthesia procedures as well as other services. In addition to the five claims measures above, which also are available as registry measures, the following measures are available:

Measure 44 – Preoperative Beta-Blocker in Patients with Isolated CABG surgery
Measure 342 – Pain Brought Under Control within 48 hours
Measure 358 – Patient Centered Surgical Risk Assessment and Communication

As well as five brand new measures for the qualified registry reporting option:

Measure 404 – Anesthesiology Smoking Abstinence
Measure 424 – Perioperative Temperature Management
Measure 426 – Post-Anesthetic Transfer of Care Measure: Procedure Room to a Post Anesthesia Care Unit (PACU)
Measure 427 – Post-Anesthetic Transfer of Care: Use of Checklist or Protocol for Direct Transfer of Care from Procedure Room to Intensive Care Unit (ICU)
Measure 430 – Prevention of Post-Operative Nausea and Vomiting

As with claims, you also must report at least 1 cross-cutting measure under the qualified registry option if you have face-to-face encounters with patients. Review the CMS list of Face-to-Face encounters to see if this applies to you. NOTE: If you bill for only anesthesia services, then you will likely not have a face-to-face encounter. However, if you bill for certain evaluation and management services or other procedures, then you will probably have face-to-face encounters. Measures 130, 131, and 226 are classified as cross-cutting measures.

The measure applicability validation (MAV) process remains in place for the 2016 reporting year for providers who report 1-8 measures across 3 National Quality Strategy (NQS) domains or 9 measures across 1-2 NQS domains in the qualified registry option. MAV will be applied only if all measures that have been reported are reported successfully (regardless of volume) and if providers with face-to-face encounters who are denominator eligible have reported at least 1 cross-cutting measure. (More information about the qualified registry MAV process is available on the CMS website.)

Anesthesiologists who wish to participate in the qualified registry option as a group (or any other GPRO option) must self nominate by June 30, 2016, on the physician value portlet at the CMS.gov Enterprise Portal. Also, 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.

Finally, reporting PQRS using the qualified registry option requires providers to select a qualified registry vendor from the approved CMS list (a list of approved qualified registries will be available on the CMS website by March 31, 2016). Those vendors typically charge a per provider rate in order to submit the PQRS data and many are able to report certain measures.

3. The Qualified Clinical Data Registry (QCDR) reporting option is available to anesthesiologists who participate as individuals or as a group through GPRO.

QCDR for GPRO is new for the 2016 reporting option. The 2016 Reporting Requirements for QCDR are as follows:

Report at least nine (9) measures covering at least three (3) National Quality Strategy (NQS) domains,
Report each measure for at least 50 percent of the EP’s patients (Medicare and non-Medicare).
Of these measures, 2 out of 9 must be outcomes measures.

While not every specialty has a QCDR available, anesthesiologists can participate in PQRS using the QCDR reporting option via the American Society of Anesthesiologists’ (ASA) Anesthesia Quality Institute. ASA members can use the AQI QCDR for free. Non members can pay for the service. All participants using the AQI QCDR must also submit data to the National Anesthesia Clinical Outcomes Registry (NACOR).

QCDRs are not limited to accepting only PQRS measures and thus provide greater opportunities for data submission. For instance, in 2015 the AQI QCDR offered 27 measures in addition to the 9 PQRS measures available. AQI QCDR measures for 2016 should be available on the AQI website shortly.

AQI has the following requirements for providers who wish to report through their QCDR:

Sign all ASA QCDR and NACOR agreements.
Submit monthly case data from your billing software to AQI.
Determine the 9 measures that you are going to report (Check the denominator codes of each measure to determine if you are eligible to report the measure)
Take the ASA QCDR Readiness Assessment to begin registration for the QCDR reporting service. Note: To participate in the ASA QCDR, you must either be a member of ASA or pay the QCDR reporting fee. You must also participate in and submit data to NACOR.
Review your PQRS reports monthly by logging into AQI’s member’s only page.
Attend regularly scheduled AQI conference calls to monitor your compliance.
Sign off on quarterly PQRS reports provided by AQI.
Approve the final transmission of your PQRS data to CMS.

As with other GPRO reporting options, anesthesiologists who wish to participate in the QCDR option as a group must self nominate by June 30, 2016. However, because measures must be reported on greater than 50 percent of patients, AQI requires practices to begin reporting measures on all cases by June 1, 2016.

Groups of 100 or more eligible professionals utilizing any of the GPRO reporting options, including QCDR, 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.

4. Other reporting options will likely not work for anesthesiologists.

Other reporting options like qualified registry measures groups; EHR (including direct EHR products and EHR data submission vendor products); and the GPRO web interface likely would not meet the needs of anesthesiologists because of the scope of the measures available or the narrow guidelines for reporting. If you are interested in reviewing these options, however, please visit the CMS PQRS web page.

Important Points to Remember

There are no hardship or low volume exemptions for the PQRS program. All providers who submit claims to Medicare under the Physician Fee Schedule must participate either as an individual or as a group using one of the reporting options.
If your group of anesthesiologists is reporting as individuals, be sure each physician chooses measures that are possible to report on. Reporting as a group may alleviate the pressure on individual professionals who have low volumes of patients or denominator-eligible patients.

For more information about the 2016 PQRS reporting year for the 2018 payment adjustment, visit the CIPROMS’ blog post, “PQRS: Getting Started for 2016,” or review CMS’s PQRS webpage (resources are being updated regularly for the new program year). Also, you can review the slides from a recent MLN Connects National Provider Call on the 2016/2018 PQRS and VBPM Programs.

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