Quality reporting is here.
That message is about to be reinforced to anesthesia practices across the country this year. It’s confusing, but the CSA and ASA nicely summarize the terminology for PQRS in a recent CSA blog that reprinted a portion of an article from the ASA newsletter.
PQRS — the Patient Quality Reporting System — comes from the Centers for Medicare and Medicaid Services (CMS). It imposes punitive Medicare anesthesia payment deductions of 2 percent in 2017 if providers do not report 2015 performance data. In addition, an anesthesia group (at the Tax ID Number [TIN] level) will be penalized 6 percent in 2017 if more than 50 percent of the group’s members do not successfully report PQRS. Potentially this could be upwards of $10,000 in annual collections per anesthesiologist.
This is the nuts-and-bolts story of how our group set up our PQRS reporting mechanism from scratch. In late November 2014, right before Thanksgiving, we met with Dr. Rick Newell, the director of quality and performance from our new partner organization, CEP America. With our heads spinning from the acronyms, Rick explained that CMS was rapidly transitioning to value-based payments.
“We need to get this set up with NACOR QCDR by January first ,” he said. With the impending holidays, we collectively sat there dumbfounded, like we had just eaten bad turkey. What was a QCDR? What was a NACOR?
CMS accepts anesthesia quality measures as reported through several mechanisms including through a Qualified Clinical Data Registry (QCDR). The best-known and most widely accepted anesthesia QCDR is the one set up by the Anesthesia Quality Institute (AQI), called NACOR.
A little background: A prescient ASA many years ago formed a subsidiary for the study and development of anesthesia outcomes called the Anesthesia Quality Institute (AQI). In 2014 the AQI submitted for and received approval from the CMS for its QCDR — the National Anesthesia Clinical Outcome Registry (NACOR). The cost of reporting anesthesiologists’ data through NACOR is $1,295 a year for non-ASA members, or free to ASA members.
“Everybody in the group are ASA members, right?”, asked Rick. I gulped; we had a handful of non-ASA/CSA members. “We have to get these people registered by January.”
From that initial meeting, we managed to get the PQRS reporting system for our practice up within one month. Here are the steps we took.
Step 1. Register every anesthesiologist in the ASA/CSA.
Step 2. Register every anesthesiologist in NACOR.
Step 3. Determine which measures we wanted to use (depends on the practice). NACOR has these listed. For 2015 anesthesiologists will need to report at least 9 measures per practitioner across three National Quality Strategy (NQS) domains.
Step 4. Determine our data collection method. We created our own data sheet with 12 total measures to cover every practitioner in our practice. This data sheet is submitted with our anesthesia record for billing.
Step 5. Select an agent to collate, collect and report the data to NACOR, in NACOR format. We tasked our billing company to do this as a condition of our contract.
Step 6. Elect a QA Director to oversee the process of data collection and reporting for NACOR.
For more information, a good place to start would be the AQI. They can help guide you through the process.
For 2015 providers will need to report at least 50 percent of cases in a qualified CMS system to avoid individual penalties of 2 percent in 2017 and group (TIN) penalties of 6 percent in 2017. The goal of CMS is to have every physician reporting quality measures via an approved method.
It’s not too late. You may have 10,000 reasons to get the process started now.
Dr. Chow is a frequent contributor to CSA Online First. Currently he is in private practice with CEP America and is the Chair of the Department of Anesthesia at Good Samaritan Hospital, San Jose. He also holds an adjunct community faculty position at Stanford School of Medicine.