Ask Joy: This Week on PQRS
Welcome to Ask Joy. In this week’s column, we’ll be answering some common questions about the Physician Quality Reporting System incentive program. This voluntary program was introduced by CMS in 2006 and each year since, the rules, incentives, and payment adjustment have changed. Since providers are responsible for ensuring that they use the PQR documents from the current year, we thought we’d make keeping up to date on the details a little simpler. And you can find more information on my recent Learning Lunch about PQRS from July 17th.
Q1: What is PQRS?
A: The Physician Quality Reporting System is a voluntary program introduced by CMS in 2006 for Medicare Part B physicians to receive an incentive for submitting a data on a minimum of 3 quality measures. For 2013, the incentive is .5% and reporting this year’s data will determine if a provider will be subject to a negative 1.5% payment adjustment in 2015. Find out if you’re eligible.
Q2: I don’t understand all the options and methods for reporting. Where should I start?
A: CMS published a great visual description of the PQRS program that details each method for reporting and the options and requirements for each.
Q3: How can providers avoid the 2015 penalty?
A: Depending on whether you are reporting as an individual provider or as a GPRO, there are three options available for those looking to avoid the penalty.
How to avoid the 2015 Payment Adjustment (Individual EPs)
- Option 1: Meet the requirements for satisfactorily reporting for incentive eligibility as defined in the 2013 PQRS measure specifications
- Option 2: Report at least one valid measure (or measures group) via claims, participating registry, or participating/qualified EHR
- Option 3: Elect to participate in the CMS-calculated administrative claims-based reporting mechanism
- The election of the CMS-calculated administrative claims-based reporting is available only via the web from July 15, 2013 – October 15, 2013. To sign up, follow:
- Step 1: Prior to signing up for your PQRS reporting mechanism, both group practices and individuals will need to register for a CMS IACS account if they do not already have an IACS account, or add the appropriate IACS role if they already have an existing account. Registration for IACS begins June 3, 2013.
- Step 2: Beginning Juy 15, go to the CMS Portal and select the PV PQRS option, near the bottom of the page to register.
How to avoid the 2015 Payment Adjustment (GPROs)
- Option 1: Meet the requirements for satisfactorily reporting for incentive eligibility as defined in the 2013 PQRS measure specifications
- Report specific GPRO Web Interface measures on a pre-populated patient sample, reference the 2013 PQRS GPRO Web Interface Specifications (available to groups of 25 or more EPs) OR
- Report at least 3 registry measures for the PQRS GPRO, reference the 2013 PQRS Measure Specification for Claims/Registry Reporting of Individual Measures
- Option 2: Report at least one valid measure via (PQRS GPRO only):
- Web interface OR
- Registry (available to all PQRS GPRO group practice sizes)
- Option 3: Elect to participate in the CMS-calculated administrative claims-based reporting mechanism
- The election of the CMS-calculated administrative claims-based reporting is available only via the web from July 15, 2013 – October 15, 2013. To sign up, follow:
- Step 1: Prior to signing up for your PQRS reporting mechanism, both group practices and individuals will need to register for a CMS IACS account if they do not already have an IACS account, or add the appropriate IACS role if they already have an existing account. Registration for IACS begins June 3, 2013.
- Step 2: Beginning July 15, go to the CMS Portal and select the PV PQRS option, near the bottom of the page to register.
- The election of the CMS-calculated administrative claims-based reporting is available only via the web from July 15, 2013 – October 15, 2013. To sign up, follow:
Q4: My practice is reporting CQMs as part of the EHR Incentive Program. We are also reporting PQRS via claims. If we are reporting PQRS by claims do we need to be concerned about the PQRS-Medicare EHR Incentive Pilot?
A: Sounds like you are reporting both CQM & PQRS satisfactorily. However, if you are reporting the same set of measures for both, it may be worth looking into participating in the PQRS-Medicare EHR Incentive Pilot. View this quick reference guide for more information or check out the measures that are qualify for both CQMs and PQRS.
Q5: The provider must have an individual NPI and TIN but can report as a group. If you report as a group how does the payment return, to which TIN?
A: If you report as a group, individual providers reassign their incentive check to the TIN that corresponds to the self-nominated registration.
Q6: Since we are already half-way through the year, will there be a penalty in reimbursement in 2015 due to not having 6 months of participation?
A: Not necessarily. Depending on which measures you choose to report on, some measures require data on just one instance within the reporting period. Review the measures and select ones that both apply to you and are an “easy win.” You can view all measures and measures group information by clicking on this link.
Q7: How can providers find consultants that can help?
A: The list of qualified PQRS registries & EHR data submission vendors are great resources. Each has contact information for companies that are qualified to help with PQRS. Even if you do not choose to report via a registry or EHR, they have experts who can walk you through the requirements and how to get physicians up to par. If anything, select a company from the list and request an informational interview / meeting to see how your practice stacks up. Here is the list of qualified registries and the list of qualified EHR data submission vendors.
Q8: Can my practice participate in all CMS incentive programs?
A: The EHR Incentive Program, eRx, and PQRS are all funded via Medicare. If you choose to go with the Medicare EHR Incentive, then you cannot participate in eRx, but you can combine it with PQRS. The only way to participate in all three, is to choose to participate in the Medicaid EHR Incentive Program. If you are only seeking PQRS & eRx incentive funds, that is allowable. For a great visualization of payments available & participation eligibility, check out this table. CMS has also published a summary of incentive programs that are interrelated.
About the Author: Joy Rios has worked directly with multiple EHRs to develop training programs for both trainers and practice staff. She has successfully attested to Meaningful Use for multiple ambulatory practices in both Medicare and Medicaid. She also authored the Certified Professional Meaningful Use course for www.4Medapproved.com. Joy holds an MBA with a focus in sustainability. She is Health IT certified with a specialty in Workflow Redesign, holds HIPAA security certification, and is a great resource for information regarding government incentive programs.Ask Joy is a regular column on 4Medapproved HIT Answers.