Physician advocates are warning doctors to pay close attention to the CMS' recently released Physician Quality Reporting System data submission deadlines (PDF), because the 2014 data they report will be used to calculate their future Medicare payments.
“I imagine that CMS is making an effort to be very explicit about the data submission deadlines because the penalty phase has begun,” said Karen Ferguson, senior director for public policy at the American Medical Group Association. “The 2014 PQRS data that groups submit during the listed timeframes will have an impact on whether they receive a reduction in their Medicare payments in 2016.”
Physicians who do not satisfy CMS reporting requirements for 2014 will receive a 2% penalty and will receive only 98% of the payment amounts listed in the 2016 Medicare Physician Fee Schedule.
The agency has sought to be more flexible in its requirements, but critics argue that it also has simultaneously made the program more complicated.
“These deadlines are fairly typical, with a little more time given for some of the options,” said Allison Brennan, a senior advocacy adviser for the Medical Group Management Association. “One thing to note is that, with all the different elements and all the different deadlines, it illustrates the growing complexity of the program.”
The program also is shifting its requirements from providing a bonus for participation, to penalizing nonparticipation. The CMS refers to the bonuses as “incentive payments” and the penalties as payment “adjustments.”
Physicians can submit their 2014 data as individuals or as part of a group practice, with a variety of reporting-method options and formats for doing so. Each has its .
For example, doctors submitting data directly from their certified electronic health record or through a data-submission vendor must turn in their information by Feb. 28. Those reporting through a qualified clinical-data registry have the same deadline. Group practices must file by March 20, and those reporting through a specialty board-related maintenance of certification organization have until March 31.
“Whatever is done in 2015 will be done to avoid a future penalty,” Brennan said. “So they need to be aware of the deadlines. Those relying on third-party vendors need to have a discussion to ensure their vendors can submit the data.”
Doctors and medical groups are becoming increasingly frustrated with the PQRS and its every-changing requirements, she added.
“We have to start from square one every year on what to report and when,” she said. Changes included adding 37 new quality measures and retiring 45 others.
The continual changes and increasing complexity of the PQRS are exemplified by a frequently asked question item on the CMS website about a defunct code.
“Effective on 7/1/2014, EPs who bill on a $0.00 QDC line item will receive the N620 code,” . “It replaces the current N365, which will be deactivated effective 7/1/2014. EPs who bill on a $0.01 QDC line item will receive the CO 246 N572 code. The new RARC code N620 is your indication that the PQRS codes were received into the CMS National Claims History (NCH) database. The new CARC 246 with Group Code CO or PR and with RARC N572 indicates that this procedure is not payable unless non-payable reporting codes and appropriate modifiers are submitted.”
“At the end of the day, it's not improving quality of care,” Brennan said. “It's just adding a layer of complexity.”
The MGMA, at its annual meeting in October, released survey findings that showed 82% of respondents were engaged in their own internal quality-improvement efforts, and that 83% said the PQRS and other Medicare programs were distractions that impeded quality improvement.
The PQRS was launched in 2007. At this year's conference, Anders Gilberg, MGMA's senior vice president of government affairs, said that the PQRS and other Medicare quality-reporting programs had lost their focus and were not providing the timely, actionable feedback that had been promised.
The CMS released this past July which showed a record 435,931 clinicians (36% of eligible professionals) participated in the program that year, with more than 84% receiving bonuses totaling $167.8 million. Participation was highest among those who see more Medicare patients: internists, family medicine doctors, emergency physicians, anesthesiologists and radiologists.
The CMS added 2013 PQRS quality-measure data from group practices (PDF) to its on Dec. 18. The data was submitted by 214 shared savings accountable care organizations, 139 group practices and 23 Pioneer ACOs. The data included groups' performance on diabetes- and heart disease-treatment measures as well as on patient-experience measures such as physician communication and timeliness of care.
The CMS announced it will “significantly expand” the number of quality measures reported on Physician Compare, and said it will post more quality measures for group practices and individual physicians in late 2015.
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