Justin’s Vaughn’s December 22, 2015 alert titled “CMS Incentive Programs for 2016: Summary and Suggestions” provided an overview of the PQRS changes for 2016. This alert serves to reinforce and supplement a key point in that alert that the time to switch to registry reporting is now.
Since 2010, physician groups have been accustomed to submitting Physician Quality Reporting System (PQRS) measures to Medicare using a “claims-based” methodology. This process involves eligible professionals (“EPs”) charting whether or not they have met a particular quality measure on their anesthesia record or charge ticket and then forwarding to their billing entity for processing. The biller, in turn, then translates the measure outcomes into specific CPT category II codes that are submitted as line items on claim forms sent to Medicare. The end result of this process is that CMS aggregates all data received and determines whether an EP passed or failed their applicable quality measures and whether or not a penalty should be levied.
For anesthesiologists, 2016 presents a big challenge for claims-based PQRS reporting. Per CMS, three of the four relevant anesthesia quality measures can now only be reported through a registry (Antibiotics, Beta-Blockers, and Perioperative Temperature Management). This news does not come as a surprise, as CMS has hinted for years that claims-based PQRS reporting will eventually be going away. This leaves only the Sterile CVP protocol (measure #76) remaining as a viable PQRS option for claims-based reporting. So what happens if you don’t place any CVPs?
Per CMS, eligible professionals who don’t place CVPs (and will therefore have no PQRS measures to report via claims) will be deemed as failing the PQRS program for 2016 and will be subject to a 2% penalty (assessed in 2018) if they don’t convert to registry reporting now. There is also an additional 4% penalty that a group can incur as part of the value-based payment modifier system if more than half of their members also fail to comply. All of these ominous signs point to one thing – groups should be looking to migrate to registry reporting sooner rather than later to avoid significant financial loss on their future Medicare collections.
There are many advantages to reporting through a Qualified Clinical Data Registry (QCDR). First, groups know where they stand throughout the year regarding reporting compliance and will not receive surprising or erroneous PQRS penalty letters from CMS (Earlier this year, thousands of providers from multiple specialties had to appeal such penalty letters even though they met the PQRS reporting requirements). Second, Medicare does not aggregate the numerator and denominator data to determine whether a PQRS penalty is applicable or not. The QCDR performs that function and attests to CMS on a group’s behalf. Lastly, successful registry reporting makes up half of the composite score for the new CMS quality program that will replace PQRS in 2019 call “MIPS” (Merit-Based Incentive Payment System). Under this new system, groups can not only avoid substantial penalties, but can also eventually reap the reward of incentive payments from Medicare as part of the “pay for performance/value” aspect of the MIPS program.
The writing is on the wall – 2016 is the year to start the migration process to registry reporting. Please contact your Medac practice manager for additional information.
For any additional questions on the PQRS changes for 2016, the original alert is attached.
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The information presented herein reflects general information that is current as of the date it was first published. In light of changes that may occur in the health care regulatory and compliance environments, the author’s presentation of this information might become outdated. Please check with your individual legal and/or compliance advisor(s) prior to taking any significant actions based upon the information and advice presented.