Participation in the Physician Quality Reporting System is now a requirement for all providers accepting payments based on the Physician Fee Schedule for Medicare Part B beneficiaries. This includes practitioners and therapists as well as physicians. A disincentive in the form of a 4% negative payment adjustment will be applied in 2018 to any provider that fails to report adequate quality measures for 2016 (which includes the 2% negative adjustment for the Value Measure program).
The selection of measures to report should be done strategically, as the information submitted will be use in the Value-based Payment Modifier program to calculate payment adjustments that can be negative, neutral or positive. Negative adjustments are applied depending on the size of the group. For 2016, only groups of 100 or more providers can receive a negative adjustment, based on quality performance reporting for 2014. This expands to groups of 10 or more in 2017, based on 2015 performance. The gradual phase-in of this program means that all providers will be subject to payment adjustments by 2018 based on quality data reported for 2016, so the selection of quality measures on which to report will have a significant effect on future Medicare payments.
Click here for a complete list of all quality measures available in the PQRS program for 2016, in Excel spreadsheet format. Providers must report on 9 quality measures that cross at least 3 of the 6 National Quality Strategy domains:
- Patient Safety
- Person and Caregiver-Centered Experience and Outcomes
- Communication and Care Coordination
- Effective Clinical Care
- Community/ Population Health
- Efficiency and Cost Reduction
New for 2016, if the provider sees at least one (1) Medicare patient in a face-to-face encounter, at least one of these 9 measures must be a 'cross-cutting' measure that is broadly applicable across multiple providers and specialties
The reporting process for quality measures can be done through a variety of channels, each of which present varying costs and complexities:
- Submit directly from your EHR system, either through an upload function provided within your certified EHR, or through a Data Submission Vendor (DSV) that extracts and uploads the selected quality measures on the provider's behalf. This is the most cost-effective option for small practices that are already using a certified EHR and attesting for MU.
- Submit through a Qualified Registry, which is a vendor that extracts data, calculates performance and submits on the provider's behalf. The advantage of a Qualified Registry is in the wider variety of quality measures that can be tracked, enabling the provider to select measures that are advantageous to report, in relation to the Value Modifier incentives.
- Submit through a Qualified Clinical Data Registry (QCDR), which is a CMS-approved entity such as a specialty society, certification board, or regional health collaborative, that collects medical and/or clinical data for the purpose of patient and disease tracking to foster improvement in the quality of care provided to patients. Data submitted by a QCDR may include multiple payors, not just Medicare, and may include quality measures beyond those specified for PQRS.
- Submit as a group practice via GPRO Web Interface - for groups of 25 or more providers, this option allows reporting on measures for the entire group instead of selecting individual measures for each provider. This can be advantageous in multi-specialty groups, or those with specialties that don't have specific Measure Groups for comparison. Registration for this option is an annual exercise, and ended on June 30 for 2016.
- Submit through a CMS-Certified Survey Vendor, which includes a consumer survey of your patients covering 12 domains of care experience. Required for group practices of 100 or more providers, and optional for groups of 2-99 providers, the costs for the survey are paid by the group practice.
- Submit directly through your claims filed with Medicare on Part B encounters. Available to individual providers only, this method is the simplest method for participating in PQRS for those providers that do not use certified EHR technology, by adding the appropriate quality-data code to the corresponding box on the CMS 1500 or 1450 forms.
ACI can help your organization avoid negative pay adjustments in future years by implementing adequate quality reporting mechanisms this year. Call us today for a free evaluation.
Physician Quality Reporting
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