physician quality reporting system (pqrs)
TRANSCRIPT
Physician Quality Repor3ng System (PQRS) Wednesday, February 5, 2014
Disclaimer: Nothing that we are sharing is intended as legally binding or prescrip7ve advice. This presenta7on is a synthesis of publically available informa7on and best prac7ces.
• Voluntary, individual repor1ng program – Quality measures for services provided to Medicare beneficiaries
• Started in 2007 – Tax Relief and Health Care Act
• Incen1ve payments for par1cipa1on through 2014
• Financial penalty for non-‐par1cipa1on aKer 2014 • Measures based on combina1ons of CPT, ICD and pa1ent age at the 1me of the encounter
What is PQRS?
• Physicians – Doctors of Medicine, Osteopathy, Podiatric Medicine, Optometry, Oral Surgery, Dental Medicine, Chiroprac1c
• Prac11oners – Physician Assistant – Nurse Prac11oner – Clinical Nurse Specialist
– Cer1fied Registered Nurse Anesthe1st (and Anesthesiologist Assistant) – Cer1fied Nurse Midwife – Clinical Social Worker – Clinical Psychologist
– Registered Die1cian – Nutri1on Professional – Audiologists
• Therapists – Physical Therapist – Occupa1onal Therapist – Qualified Speech-‐Language Therapist
Who is Eligible?
Provider Repor1ng Methods
• Individual – EHR Direct Product that is Cer1fied EHR Technology (CEHRT) – EHR data submission vendor that is CEHRT – Qualified PQRS Registry – Par1cipa1on through a Qualified Clinical Data Registry (QCDR) – Medicare Part B claims submiYed to CMS
• Group Prac1ce Repor1ng – GPRO Web Interface – Qualified PQRS Registry – EHR Direct Product that is CEHRT – EHR data submission vendor that is CERT – CMS-‐cer1fied survey vendor
*Group prac*ces repor*ng via GPRO must register for their selected repor*ng method by September 30, 2014.
Claims-‐Based Repor1ng
• QDCs must be reported – On claim represen1ng the denominator of eligible Medicare Part B
encounters – Same beneficiary as encounter – Same date of service as qualifying EM code – Same EP who is rendering eligible performed code
• QDCs must be submiYed with a line-‐item charge of one penny ($0.01) at the 1me the associated covered service is performed – SubmiYed charge field cannot be blank. – Line item charge should be $0.01 – beneficiary not liable for this amount – En1re claim with $0.01 charge will be rejected. Claims for just QDC codes
are not permiYed
* Claims may NOT be resubmi@ed for the sole purpose of adding or correc7ng QDCs
EHR-‐Based Repor1ng
• EHR-‐based repor1ng op1on sa1sfies the CQM component of Meaningful Use
• Submit data by the February 28, 2015
• Direct EHR Vendor – Must register for an IACS account
• EHR Data Submission Vendor – Responsible for submicng PQRS measures data to CMS
Qualified Registry
• Collects clinical data from eligible professional or group prac1ce
• Submits data to CMS on behalf of par1cipants
• 2014 Par1cipa1ng Registry Vendors list available on the CMS PQRS web-‐site
Qualified Clinical Data Registry (QCDR)
• CMS-‐approved en1ty
• Collects medical and/or clinical data for pa1ent and disease tracking – Improved quality of care
• Not limited to PQRS measures
• May submit measures from one or more of the following categories: – Clinician & Group Consumer Assessment of Healthcare Providers and Systems – Na1onal Quality Forum endorsed measures – Current 2014 PQRS measures – Measures used by boards or specialty socie1es – Measures used in regional quality collabora1ons
• Choose appropriate QCDR
• Work directly with QCDR – Legal agreement for QCDR receipt of pa1ent-‐specific data and release of quality measure data to
CMS on the EPs behalf. – Specific instruc1ons on how to collect and provide pa1ent data for use by the QCDR supplied by the
QCDR.
GPRO Web Interface • Register and report chosen repor1ng method no later than September 30, 2014 if
repor1ng for 2014 • Includes comple1on of pre-‐filled beneficiary sample. • 25 – 99 Eligible Professionals
– Report on all measures AND populate data fields for the first 218 consecu1vely ranked and assigned beneficiaries
Or – Have all 12 CG CAHPS summary survey modules reported via CMS-‐cer1fied survey
vendor AND report on 6 measures covering at least 2 of the NQS domains – Use a qualified registry, direct EHR product, EHR data submission vendor or GPRO Web
Interface as a repor1ng mechanism.
• 100 + Eligible Professionals – Report on all measures AND populate data fields for the first 411 ranked and assigned
beneficiaries
Individual eligible professionals within a group prac1ce that sa1sfactorily completes the GPRO Web Interface will also receive credit for the CQM component of the EHR Incen1ve Program.
Payment Incen1ve/Penalty Timeline
Requirements for Incen1ve Payments – Individual Measures
• Claims/Qualified Registry – At least 9 measures covering at least 3 NQS domains for at least 50%
Medicare Part B pa1ents seen during repor1ng period. – If less, report 1—8 measures covering 1—3 NQS domains, AND report
each measure for at least 50% Medicare Part B pa1ents seen during repor1ng period. • Measures with a 0% performance rate not counted. • Fewer than 9 measures covering 3 NQS subject to the MAV process.
• EHR Report – 9 measures covering at least 3 of the NQS domains – If CEHRT does not contain pa1ent data for at least 9 measures covering at
least 3 domains, the EP must report measures with Medicare pa1ent data – Must report on at least 1 measure for which there is Medicare pa1ent
data
Requirements for Incen1ve Payments – Measure Groups
• Qualified Registry – Report at least 1 measures group, AND report each measures group
for at least 20 pa1ents
– Majority must be Medicare Part B pa1ents.
• Qualified Clinical Data Registry – Report at least 9 measures covering at least 3 NQS domains AND
report each measure for at least 50% eligible pa1ents seen during the repor1ng period
– Measures with a 0% performance rate not counted.
– At least 1 outcome measure.
Requirements for Avoiding Penal1es in 2016 – Individual Measures
• Claims/Qualified Registry/Qualified Registry Report – At least 9 measures covering at least 3 NQS domains AND report each measure for
at least 50% Medicare Part B pa1ents seen during repor1ng period. – If less than requirement report 1—8 measures covering 1—3 NQS domains, AND
report each measure for at least 50% Medicare Part B pa1ents seen during the repor1ng period.
– Measures with a 0% performance rate would not counted. – Fewer than 9 measures covering 3 NQS domains via the claims-‐based repor1ng
mechanism subject to the MAV process
• Claims – Report at least 3 measures for at least 50% of the eligible professionals Medicare Part B
pa1ents seen during the repor1ng period. – If less than requirement, report 1—2 measures; AND report each measure for at least
50% Medicare Part B pa1ents seen during the repor1ng period to which the measure applies.
– Measures with a 0% rate not counted.
Avoiding Penalty in 2016 -‐ Individual Providers, Group Measures
• Qualified Registry – Report at least 1 measures group, AND report each measures group for at least 20
pa1ents, a majority of which must be Medicare Part B FFS pa1ents.
• Qualified Clinical Data Registry – Report at least 9 measures covering at least 3 NQS domains AND report each
measure for at least 50 percent of the eligible professional’s applicable pa1ents seen during the repor1ng period to which the measure applies.
– Measures with a 0% performance rate would not be counted. – Of the measures reported via a qualified clinical data registry, the eligible
professional must report on at least 1 outcome measure
• Qualified Clinical Data Registry – Report at least 3 measures covering at least 1 NQS domain AND report each
measure for at least 50 percent of the eligible professional’s applicable pa1ents seen during the repor1ng period to which the measure applies.
– Measures with a 0 percent performance rate would not be counted
Avoiding Penalty in 2016 -‐ GPRO
• GPRO Web Interface Report on all measures included in web interface. – Populate data fields for the first 218 (411 for 100 or more EPs) consecu1vely ranked and
assigned beneficiaries – If less than 218 eligible assigned beneficiaries, report on 100% of assigned beneficiaries.
• Qualified Registry – Report at least 9 measures covering at least 3 of the NQS domains and report each measure for at least 50%
of the group’s Medicare Part B pa1ents seen during the repor1ng period. – If less than requirement, report 1 – 8 measures covering 1 – 3 domains with Medicare pa1ent data AND
report each measure for at least 50% of Medicare Part B pa1ents seen during the repor1ng period. – Measures with 0% performance rate not counted. – Fewer than 9 measures covering at least 3 domains, subjects the group to the MAV process
• Direct EHR / EHR Data Submission by Vendor – Report 9 measures covering at least 3 domains. – If a group prac1ce’s CEHRT does not contain pa1ent data for at least 9 measures covering at least 3
domains, then the group prac1ce must report the measures for which there is Medicare pa1ent data. – A group prac1ce must report on at least 1 measure for which there is Medicare pa1ent data.
• CMS -‐ Cer1fied Survey Vendor – Report all CG CAHPS survey measures AND report at least 6 measures covering at least 2 of the NQS
domains
Measure Selec1on
• Individual Measures – 110 Claims Based Measures
– 201 Registry Based Measures
– 64 EHR Measures
• Group Measures – 25 Measures Groups
• Domains – Clinical Process / Effec1veness
– Pa1ent Safety
– Popula1on / Public Health
– Efficient Use of Healthcare Resources
– Care Coordina1on
– Pa1ent and Family Engagement
Measure Selec1on
• Which measures should you choose? – Difficulty
– Relevance • Clinical condi1ons usually treated – Cardiac, HTN, Diabetes, etc. • Types of care typically provided – e.g., preven1ve, chronic, acute
– Best performance
• 200 standardized quality measures
• Meet 50% threshold requirement – Choose a PQRS quality measure for services that are performed frequently. (This is the
minimum required to prevent penalty)
• Incen1ve Payment or Avoid Penalty
PQRS Resources
• hYp://www.cms.gov/Medicare/Quality-‐Ini1a1ves-‐Pa1ent-‐Assessment-‐Instruments/PQRS/MeasuresCodes.html\
– 2014 Physician Quality Repor1ng System Implementa1on Guide
– 2014 PQRS Measures
• QualityNet Help Desk: – Portal password issues – PQRS/eRx feedback report availability and access – IACS registra1on ques1ons – IACS login issues – PQRS and eRx Incen1ve Program ques1ons
• 866-‐288-‐8912 (TTY 877-‐715-‐6222) 7:00 a.m.–7:00 p.m. CST M-‐F or [email protected] You will be asked to provide basic informa1on such as name, prac1ce, address, phone, and e-‐mail