Many members have approached the CSA with questions about how to comply with PQRS reporting requirements, and how to use a data registry to report. To say that this is not simple would be an understatement.
The following article by ASA staffers Matthew Popovich, PhD, and Sharon Merrick, MS, CCS-P, is reprinted from the January 2015 ASA Newsletter and should clarify this process for you. This is not the complete article; only the portion dealing with PQRS reporting is published below.
Another excellent resource on this topic is ASA QCDR on the ASA website. This discusses how the National Anesthesia Clinical Outcomes Registry (NACOR), maintained and run by the Anesthesia Quality Institute (AQI), can be used for reporting by ASA members. NACOR has been designated as a Qualified Clinical Data Registry (QCDR) by CMS for PQRS reporting. The AQI website contains specific information about how to become a member of AQI and begin using these services.
Quality and Regulatory Affairs: PQRS, Payment and the 2015 Fee Schedule
by Matthew T. Popovich, Ph.D. and Sharon Merrick M.S., CCS-P
On Halloween last year, the Centers for Medicare & Medicaid Services (CMS) released the Final Rule for the 2015 Medicare Physician Fee Schedule (PFS). The rule outlines changes to policies and payment rates for services rendered on or after January 1, 2015. The rule also impacts how physician anesthesiologists and pain medicine physicians participate in various programs, including the Physician Quality Reporting System (PQRS).
|Reference created by CSA, not included in original article.
As members begin this new year, it is critical that you and your practice understand PQRS, its applicability to your future payments and how to best avoid the payment adjustment. As many members are aware, PQRS is a reporting program that, beginning in 2015, will use payment adjustments, or penalties, to induce quality reporting by eligible professionals (EPs). Under PQRS, covered professional services are those paid under or based on the PFS. Physician anesthesiologists whose professional services are paid under the PFS are considered EPs and are subject to payment adjustments. If an EP or group practice does not satisfactorily report or satisfactorily participate in PQRS in 2015, a 2 percent payment adjustment will apply to their covered professional services furnished during 2017.
CMS allows EPs to report quality measures through a variety of mechanisms, including claims-based, “traditional” qualified registry, Group Practice Reporting Option (GPRO), Electronic Health Record (EHR) and the Qualified Clinical Data Registry (QCDR). Reporting criteria for each of these options differ, and members should determine which reporting option best fits their practice. Since most physician anesthesiologists report PQRS measures via the claims-based option and an increasing number are registering to participate in the Anesthesia Quality Institute’s CMS-approved National Anesthesia Clinical Outcomes Registry (NACOR) QCDR, this article is limited to describing these two reporting options for 2015.
Claims-Based Reporting Option
In the past, members may have reported on or seen the option of participating in PQRS by reporting on measures such as PQRS #30 – Timing of Prophylactic Antibiotic, PQRS #76 – Prevention of catheter-related bloodstream infections, and PQRS #193 – Perioperative Temperature Management. In 2014, depending on your practice and patient population, you may have been able to report on PQRS #44 – Coronary artery bypass graft: preoperative beta-blocker in patients with isolated CABG surgery.
For 2015, to avoid the payment adjustment, CMS requires that EPs report at least nine measures, covering at least three of the National Quality Strategy (NQS) domains and report each measure for at least 50 percent of the EP’s Medicare Part B Fee-for-Service patients seen during the reporting period to which the measure applies. One of the nine measures must be a “cross-cutting” measure.
For physician anesthesiologists, reporting nine PQRS measures covering three NQS domains is a difficult, if not impossible, feat to attain. However, as in past years, CMS is continuing the Measure-Applicability Validation (MAV) process. Under this process, the EP who does not have at least nine measures covering at least three NQS domains applicable to their practice may still meet the criteria for satisfactory reporting provided that the EP reports all measures applicable to his or her practice. For this process to occur, the EP must report between one and eight measures.
This year, CMS requires, as part of the nine measures noted above in the claims-based reporting criteria, EPs to report at least one “cross-cutting” measure. Out of the available 19 cross-cutting measures, physician anesthesiologists may be able to report on just a few of them. Two such measures are PQRS #130 – Documentation of Current Medications in the Medical Record, and PQRS #131 – Pain Assessment and Follow-Up. However, members are encouraged to review the CMS website for other cross-cutting measures that may be more applicable to their practices.
Within the rule, CMS indicated its “intention to eliminate the claims-based reporting mechanism in future rulemaking” and encouraged EPs to “become familiar with reporting mechanisms other than the claims-based reporting mechanism.” Part of this draw down includes the removal of dozens of claims-based measures available for reporting in 2015, a practice that will affect more than just physician anesthesiologists. PQRS #30, a measure reported in high numbers in previous years, is a victim of this purge.
QCDR Reporting Option
Many physician anesthesiologists and practices have begun to familiarize themselves with the QCDR mechanism for PQRS reporting. In 2014, CMS introduced the QCDR as a reporting option aimed at allowing specialty societies space to develop meaningful measures that reflect profession-specific priorities and instances of care. NACOR took advantage of this opportunity and became a CMS-approved QCDR in 2014. An important distinction in the QCDR option is that EPs can report on PQRS and non-PQRS QCDR measures. For 2014, EPs were able to report on eight PQRS measures and 11 non-PQRS QCDR measures via NACOR.
Reporting requirements for the QCDR differ from the claims-based reporting option. CMS requires EPs report at least nine measures available for reporting under a QCDR covering at least three of the NQS domains, and report each measure for at least 50 percent of the EP’s patients. Of these measures, the EP would report on at least two outcome measures.
In contrast to the claims-based reporting option, EPs opting to participate in the QCDR must report on half of their patients – this includes both Medicare and non-Medicare patients. The QCDR option does not include a MAV process. Last, while most claims-based measures a physician anesthesiologist would report are process measures, the QCDR reporting option requires the EP to report on at least two outcome measures.
In 2014, a CMS-approved QCDR such as NACOR was limited to collecting 20 non-PQRS QCDR measures. For 2015, CMS expanded this number to 30 – a number that will expand the scope of the QCDR and allow for further inclusion of measures that may prove meaningful to physician anesthesiologists working in a variety of settings and with diverse patient populations. Additional measures for QCDR reporting will be released later this year.
|Comparison chart created by CSA, not included in original article.
Reporting for PQRS 2015
Members are encouraged to review the available PQRS reporting options and choose one that may best fit their practice. Early preparation in reporting PQRS is key – the claims-based reporting option requires reporting on 50 percent of Medicare Part B FFS patients. The QCDR option requires reporting on 50 percent of all the EP’s patients. An early start to PQRS 2015 reporting will place you and your practice on a path toward satisfactory reporting and satisfactorily participating in this CMS quality reporting program.
This article was reprinted with permission by ASA and originally published in ASA's January 2015 Newsletter.