As the Centers for Medicare and Medicaid Services (CMS) updates their program descriptions for the 2016 Physician Quality Reporting System (PQRS) reporting year, emergency physicians have several options for participating.
1. The claims option is available for eligible providers who want to participate as individuals in the PQRS program.
The American College of Emergency Physicians and CMS recommend the following seven measures that are available in the claims reporting option in the 2016 reporting year:
- Measure 54 – Emergency Medicine: 12-Lead Electrocardiogram (ECG) Performed for Non-Traumatic Chest Pain
- Measure 91 – Acute Otitis Externa (AOE): Topical Therapy
- Measure 93 – Acute Otitis Externa (AOE): Systemic Antimicrobial Therapy – Avoidance of Inappropriate Use
- Measure 254 – Ultrasound Determination of Pregnancy Location for Pregnant Patients with Abdominal Pain
- Measure 255 – Rh Immunoglobulin (Rhogam) for Rh-Negative Pregnant Women at Risk of Fetal Blood Exposure
- Measure 415 – Emergency Medicine: Emergency Department Utilization of CT for Minor Blunt Head Trauma for Patients Aged 18 (NEW FOR 2016)
- Measure 416 – Emergency Medicine: Emergency Department Utilization of CT for Minor Blunt Head Trauma for Patients Aged 2 through 17 Years (NEW FOR 2016)
Under the claims reporting option, you also must report at least 1 cross-cutting measure if you have face-to-face encounters with patients. (Emergency evaluation and management codes are on the CMS list of Face-to-Face encounters.) While none of the recommended measures above are also on the cross-cutting measures list, Measure 1 – Diabetes: Hemoglobin A1c Poor Control, is on the list and is available for claims reporting by emergency physicians and other eligible professionals.
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 emergency physicians who participate as individuals or as a group through GPRO.
In addition to the seven measures listed above (which are all also available in the qualified registry option), the following measures also are recommended for emergency physicians utilizing the qualified registry option:
- Measure 66 – Appropriate Testing for Children with Pharyngitis
- Measure 116 – Avoidance of Antibiotic Treatment in Adults With Acute Bronchitis
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. (Emergency evaluation and management codes are on the CMS list of Face-to-Face encounters.) While none of the recommended measures above are also on the cross-cutting measures list, Measure 1 – Diabetes: Hemoglobin A1c Poor Control, is on the list and is available for registry reporting by emergency physicians and other eligible professionals.
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 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.)
Emergency physicians and nonphysician providers 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 emergency physicians and nonphysician providers 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, emergency physicians can participate in PQRS using the QCDR reporting option via ACEP’s Clinical Emergency Data Registry (CEDR). The cost is $.10 per visit based on the annual ED census for the year prior for all EDs in your group.
QCDRs are not limited to accepting only PQRS measures and thus provide greater opportunities for data submission. For instance, in 2015 the CEDR QCDR offered 18 measures in addition to the 9 PQRS measures available. CEDR QCDR measures for 2016 should be available on the CEDR website shortly.
For more information about participating in PQRS via the QCDR reporting option, visit the CEDR website and select the “Participate” tab.
As with other GPRO reporting options, emergency physicians who wish to participate in the QCDR option as a group must self nominate by June 30, 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 emergency physicians.
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 emergency physicians 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 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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