As we shift the focus from volume and profitability to patient outcomes, physicians are having to dig a litter deeper into reporting. Healthcare is shifting towards value-based reimbursement models and the Physician Quality Reporting System (PQRS) is a step in that direction. Unfortunately, at first glance, PQRS and CQM programs can be intimidating to say the least. Not only can PQRS be intimidating, but a large number of physicians believe that PQRS is time-consuming. PQRS participation rates reflect the number of providers that aren't making PQRS a priority.
While CMS did see a 47 percent increase in participation in the Physician Quality Reporting System from 2012 to 2013, nearly half a million eligible professionals chose to suffer the financial penalty instead.
In 2013, 469,755 eligible professionals were subject to a PQRS negative payment adjustment of 1.5 percent of their 2015 Part B Medicare Fee Schedule allowed charges. Of the physicians subject to the penalty, 98 percent did not attempt to participate in PQRS, according to CMS. Many such professionals (43 percent) treat 25 or fewer Medicare beneficiaries each year.
PQRS and MIPS
While some may think suffering the 1.5 percent payment penalty for PQRS is easier than participating, think again. The Merit Based Incentive Payment System (MIPS) will be starting in 2017 and PQRS is under the MIPS umbrella.
MIPS plans to utilize three existing programs (Meaningful Use, the Physician Quality Reporting System, and the Value-Based Modifier (VM) Program) and one new program (called Clinical Practice Improvement). In short, MIPS consolidates and strengthens the financial impacts of these programs, while continuing their performance measurement and reporting mechanisms that have become familiar to providers over the last few years.
Having a better understanding of PQRS reporting and how you can align the program with CQMs can not only help you save time but also help you prepare for the Merit Based Incentive Payment System.
Reporting for PQRS
There are many different methods for reporting PQRS data. However, which method is right for an Eligible Professional (EP) or a group of EPs will depend on the number of EPs reporting.
For instance, if a group of 25 EPs wants to submit PQRS data via a Qualified Clinical Data Registry (QCDR), this would not be possible because the QCDR reporting method is only available to individual EPs.
As a reference for reporting methods that are available to certain group sizes please refer to the following chart:
Group Reporting vs. Individual Reporting
What is most interesting about PQRS reporting methods is that groups (defined as 2 or more eligible professionals who have reassigned their billing to a single Tax Identification Number (TIN) have the option to report individually if they so choose. However, they may also register and report as a group. EPs need to figure out whether reporting as a group or as an individual makes the most sense for them and their group when it comes to PQRS.
What is CAHPS?
Included in some of these options is the word CAHPS. This is the Consumer Assessment of Healthcare Providers and Systems Survey for group practices participating in PQRS.
The CAHPS “was developed to collect information about patient experience and care within that group practice” (www.pqrscahps.org). This survey is only applicable to groups as you can see in the chart listed above.
PQRS Reporting Methods
Although there is a total of 281 measures for PQRS, they are not all eligible to be reported on for all reporting methods. As a reference here is the total count for each reporting option in 2016:
- Claims (Individual Measures): 79
- Registry (Individual Measures) 198
- Registry (Measures Groups): 25
- EHR Measures: 63
- GPRO Web Interface Measures: 18
- Certified Survey Vendor: 12 Summary Survey Modules
- Qualified Clinical Data Registry: Varies
Claims Based Reporting
It should be noted that CMS is urging the move away from the claims-based reporting option as it is the most complicated, cumbersome, and least successful option. This can be seen by their decrease in the number of individual measures for this option from 2015 to 2016.
CMS has also stated that the claims based reporting option will eventually be phased out, so it is in an EPs best interest to shift away from the claims-based reporting option as well.
Registry reporting is one of the most successful reporting methods, as individuals that decide on this route have a 90-95% success rate, according to 4MedApproved.com. Registry reporting can be done as an individual or as a group. For individuals they will have 198 individual measures to choose from while the measures groups consists of 25 different groups of measures, with at least 6 measures in each group.
How to Align PQRS and Clinical Quality Measures for Meaningful Use
Is the burden of reporting on PQRS and Meaningful Use too much? If so, then you need to consider the possibility of aligning PQRS measures and CQMs.
Aligning PQRS and CQM measures can be extremely efficient and save EPs time and money. By focusing on the same measures across the board, there is much less work to do in understanding the details of the requirements. Aligning your PQRS and CQM can also save a signification amount of time. There is much less manual data entry if you are using a method (other than EHR-Direct reporting method) that requires you to transfer data into spreadsheets/registries.
Who can align PQRS and CQMs?
EPs (individuals and part of a group) who are beyond their first year of Meaningful Use may align PQRS and CQMs. These EPs must also have EHRs that are certified to the June 2014 version of eCQMs.
Who cannot align PQRS and CQMs?
EPs who are in their first year of Meaningful Use in 2016, including those part of a group that is participating in:
- PQRS GPRO
- MSSP ACO
- Pioneer ACO
As well as, EPs without EHR certified to the July 2014 version of the eCQMs cannot align PQRS and CQMs.
Questions to Consider
There are a few questions you need to consider before deciding to align PQRS and CQMs.
- Do you plan to report as an individual or a group?
- What method of reporting will you use for PQRS?
- Which measures pertain to your practice?
- Are you using a 2014 Certified EHR Technology?
- Will you be reporting a full year of CQMs?
Options for Aligning PQRS with CQMs
When it comes to the options for alignment, individual EPs may choose to align PQRS and CQM Measure by reporting via:
- Must include 9 measures across 3 NQS domains
- There are 64 approved measures
- Qualified Clinical Data Registry (QCDR)
- 9 measures across 3 NQS domains
- These measures vary
Groups of EPs may choose to align PQRS and CQM Measures by reporting via:
- EHR-based (groups of 2-24)
- 9 measures across 3 NQS domains
- There are 64 approved measures
- GPRO Web Interface (groups of 25 or more)
- All 17 measures
- Must include surveys (CAHPS)
Eligible Providers should be aware that PQRS will not only impact reimbursement, but participation with the PQRS program will help EPs in the future as the new Merit Based Incentive Payment Program is implemented. Understanding PQRS today will help your practice prepare as the shift to value-based payments takes place.