Physician Quality Reporting System (PQRS): What You Need to Know About Participating in 2014

To date, the PQRS has been a voluntary federal program, offering bonus Medicare payments to physicians who report on a designated set of quality measures. While the PQRS will technically remain voluntary, CMS is required under the Affordable Care Act (ACA) to phase out incentive payments and instead apply penalties to physicians who fail to satisfy PQRS reporting requirements. CMS will continue to base PQRS payment adjustments on the reporting of quality measure data, but will also now use PQRS measure data to calculate a separate performance-based payment adjustment known as the Value-Based Payment Modifier (VBM). Given the payment implications of both of these new policies, it is critical that AAHPM members understand the PQRS and its various reporting requirements.

Upcoming PQRS Incentives and Penalties

*Payment adjustments are applied to total allowed charges for covered Medicare Part B Physician Fee Schedule services provided during the reporting period.

2014 PQRS Reporting Methods

Eligible professionals (EPs) can choose from multiple reporting options to satisfy PQRS reporting requirements, including

• reporting as an individual physician or as a group practice under the Group Practice Reporting Option (GPRO)
• reporting individual measures or measures groups (ie, sets of clinically relevant measures that must be reported together)
• reporting via claims, qualified registry, electronic health record (EHR), or qualified clinical data registry (QCDR) NEW for 2014

An EP should select the option that is most relevant and meaningful to his/her patient population, but also the least burdensome to his/her practice. Please note that the italicized methods will only hold an EP harmless from the 2016 PQRS penalty, but will not qualify an EP for the 2014 PQRS incentive.

How to Get Started

1. Determine your eligibility
   Please read which professionals are considered eligible for purposes of the PQRScarefully, as not all professionals are considered eligible if reimbursed under fee schedule methods other than the Medicare Physician Fee Schedule.

   In terms of the GPRO, CMS defines “group practice” as those with 2 or more EPs, identified by individual National Provider Identifiers (NPIs), who reassign their billing rights to a single Tax Identification Number (TIN). All individual physicians who have reassigned their billing rights to a TIN and whose group self-nominates and reports satisfactorily as a group will be considered satisfactory PQRS reporters even if the individual does not have measure data reported on their individual services.

2. Review each method’s specific reporting criteria to determine which reporting option is best for you.
   In addition to reviewing the information provided on this website, you may want to review CMS’s 2014 PQRS Implementation Guide, as well as the following materials:
   • Additional information about the qualified registry reporting option, including a list of qualified vendors and a guide titled, “2014 PQRS Registry Reporting Made Simple.”
   • Additional information about the EHR reporting option, including a list of vendors and a guide titled, “2014 PQRS EHR Reporting Made Simple.”
   • Additional information about the GPRO, including web-interface measure specifications.

   When selecting a reporting method, make sure to consider whether there are a sufficient number of measures applicable to your practice that are available via that reporting method.

3. Select your measures
   Review individual 2014 PQRS measures that may be relevant to your patient population. You are encouraged to review the complete list of 2014 PQRS measures to determine if other measures may apply, as well as more detailed specifications for 2014 PQRS measures, including numerator, denominator, and exclusion definitions.

   You are also encouraged to review the list of 2014 PQRS measures groups. While there are currently no PQRS measures groups that are, in their entirety, directly relevant to hospice/palliative care providers, some may be applicable to those who practice under another primary specialty. Please keep in mind that measures groups can only be reported via qualified registry and must be reported as a set.

4. Start Reporting or Register
   Individual physicians DO NOT have to register with CMS to participate in the 2014 PQRS. If using the claims-based reporting option, simply start reporting the Quality-Data Codes (QDCs) listed in the specifications of the measures you have selected on applicable Medicare Part B claims. If using a third party entity to submit your measure data to CMS, such as a qualified registry, please check with the entity to determine whether it has its own set of registration and reporting deadlines.

   Group practices choosing to take part in the PQRS GPRO for the 2014 reporting year must register by September 30, 2014. Registration must be completed online through the Physician Value Modifier (PV) PQRS Registration System. During registration, group practices must indicate their reporting method for the 12-month period though they may change this method at any time prior to the September 30, 2014 deadline. Once a group has registered for 2014 as a PQRS GPRO, the group will not be able to withdraw its registration.

   Note: An Individual’s Authorized Access to the CMS Computer Services (IACS) account is required to access the PV-PQRS Registration System. An EP, or representatives of an EP, can sign up here for a new IACS account or modify an existing IACS account to add the appropriate EP role.

PQRS Maintenance of Certification (MOC) Incentive Program

Eligible professionals and group practices are eligible to receive an additional 0.5% incentive payment under the 2014 PQRS for participating in a qualified Maintenance of Certification (MOC) Program and completing certain requirements more frequently than is required to qualify for board certification.