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PQRS participation can prevent more Medicare penalties: Q&A

By Jennifer Bresnick

- The Physician Quality Reporting System might not be on the top of your list at the moment, but according to Ingenious Med Senior Systems Analyst Steve Besch, it probably should be.  Signing up for this lesser known program can save your practice 2% of the looming Medicare reimbursement penalties slated to hit providers in the next few years for non-participation in meaningful use, value-based purchasing, and several other CMS quality reporting programs.  EHRintelligence spoke to Besch about how the program works and what providers need to do in order to get on board.

What are some of the major challenges of the PQRS program?

Familiarity with the program in general has been a big issue.  A lot of providers still aren’t participating.  I think there’s a large portion of the community that’s completely oblivious to the fact that there are penalties coming into play and that some of their revenue is going to be taken away in a few years based on their lack of participation this year.  So that’s one of the first things: just educating our clients about what they need to do in the first place.

I’ve also encountered, in some of our larger groups, the fact that they have one person in charge of PQRS, and they’re sitting in one office in one part of the country.  Then there’s another person in charge of the hospital side of quality reporting, and they’re sitting somewhere else, and I don’t know that they always realize that this stuff is all going to come together in one place in the near future.  One side doesn’t know that the penalties are coming from somewhere else.  So they might not necessarily recognize the scale of the penalties.  I think the word is starting to get out, though.  People are starting to scramble and mobilize.

What are the advantages of participating in a PQRS registry, as opposed to claims-based reporting?

READ MORE: CMS Streamlines Clinical Quality Measure Reporting Guidelines

Typically, the success rate for claims-based reporting was about 50%.  I liken it to a message in a bottle.  They sent their claims data off, and it went through multiple levels of the billing system before it reached CMS.  And somewhere along the way, 50% of that data was getting deleted, and we had no idea how or why.  Half the data wouldn’t make it.

They eventually lowered the reporting requirement to 50%, because the system has been designed for decades to strip out non-billable data, and suddenly we’re trying to pass non-billable data through.  There were just so many gate keepers and things designed to eliminate all that, and it wasn’t reliable.

The registry, on the other hand, submits data to CMS directly from our system.  We mine our data directly from the provider’s billings, and once we run those numbers, we pass that directly to CMS through the secure portal.  There’s no middle man, no carrier pigeons or smoke signals or anything else that can get lost along the way.  And we get confirmation that the data has been received, so we know instantly that everything is as it should be.  Just in that respect, registries are hugely beneficial.

Why don’t more people participate?

Early on, there were a lot of people who didn’t even know what PQRS was.  I think there’s a lot of confusion – we correct a lot of misconceptions around the fact that there’s a two year lag between the penalty and the reporting.  The penalties start in 2015, and I think people see that, and think they can worry about it when 2015 gets here.  They don’t realize that the reporting they do in 2013 is what determines whether or not they get penalties in 2015.  So if they wait until then, they’ve already missed two years of reporting, and they’re going to eat two years of penalties before they can get in front of that curve again.

READ MORE: AMIA Seeks Overhaul of Clinical Quality Measure Guide

How are the PQRS program and meaningful use program entwined?

Up until now, meaningful use and PQRS have been separate.  There are several different quality reporting initiatives, and CMS has kind of undertaken an effort to align those into one or two basic reporting methods.  When they were separate, they each had different reporting windows that applied throughout the year.  They had separate sets of measures that had to be collected, separate physical reporting methods.  It was really difficult.  One person might be participating in five different programs through five different avenues at five different times of the year.  It’s more lined up now.

Now, any EHR software that is certified by the ONC as being meaningful use compliant also has to have a PQRS component included.  They’re funneling people into the EHR reporting method to get their PQRS data in from the EHR.  That will satisfy both PQRS and meaningful use reporting at the same time.

What will be the effect of these payment adjustments?

If you look at the cumulative effect of the penalties across all these reporting programs, providers are looking at 10% in penalties over the next few years.  PQRS tops out at 2%, value-based purchasing is 25, as well.  So it’s 2% here, 1.5% there, and all those add up.  It’s approaching 10% of Medicare revenue in the next few years.  That’s very significant.

READ MORE: CMS Centralized Repository Targets Stage 2 Meaningful Use

How can providers avoid these penalties?

The thing about this year is that they have the same requirements to earn the incentive – you have to reach a 50% reporting rate on three or more quality measures – but in 2013, all you have to do to avoid the penalty, is report one quality measure on one patient one time.  And then you can’t be subject to the penalty.  If groups can get something in place by the end of 2013, and get at least one quality measure per provider, they’ll be protected from the penalty.  It will be extremely unfortunate if people don’t know that, and end up being penalized for something that was so easily avoided.

The big groups, with more than 100 providers, are the ones who are going to be affected by the PQRS penalty and the value-based purchasing penalty this year.  Those groups have an option to go to the CMS website and self-nominate for the group reporting option, and select “administrative claims”.  That’s just a hugely, hugely beneficial step.  Just clicking that button will automatically protect them from the PQRS penalties this year, and it’ll also protect them from the value-based purchasing penalty this year.

So even if they don’t submit a single blip of data to CMS this year on PQRS, if they opt in to GPRO and select administrative claims, they can eliminate all those penalties.  After they do that, they can still submit any PQRS data they have for individual physicians and get the incentive if they have one coming, so it’s the best of both worlds.

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