Getting Penalized by PQRS?

Recently, we’ve heard from many groups getting penalized for not reporting PQRS, or not reporting it “correctly.” Penalties have increased and can be a 6% hit to Medicare payments!

On one hand, PQRS has been around for years, so you would assume everyone is all set. But that misses the complexity and, recently, the bureaucratic burden of verifying PQRS submissions. Fortunately, future PQRS and related VBM (Value Based Modifier) penalties can be avoided. But doing so requires work now to set up and track the appropriate PQRS “measures.”

One of many aspects that makes PQRS confusing is the number of measures (over 300). Fortunately, for a specific specialty, the number is much smaller and more manageable. But deciding exactly which measures your practice should report requires determining which ones 1)apply to your practice and 2)would be the best/easiest to report. AdvantEdge client managers work through those steps with each client at the beginning of each year. As is usual, 2016 brought some measures changes to the process.

A second aspect that makes PQRS confusing is the variety of ways to actually report. If you have an EMR that can be set up to track the measures, that is one option. If not, most practices traditionally used “claims-based reporting,” where PQRS measures are reported on the claim with the billing information. But CMS is discouraging claims-based and encouraging “registry-reporting.” PQRS data can be fed to a registry from an EMR (if the EMR can’t submit the data directly) or from a billing system.

One of many issues with claims-based reporting is that there is only one chance to submit the PQRS data. But CMS provides no feedback on the results until the third quarter, with most feedback not available until the fourth quarter! Couple that with cumbersome CMS review systems that barely worked last year and you have a monumental headache (our staff dealing with PQRS late last year would use much stronger language!).  To add insult to injury, CMS rejected many groups PQRS measures for obscure reasons and, in most cases, rejected appeals.

As a result, AdvantEdge and many others are moving to registry reporting. This means that PQRS data can be submitted at a convenient time and, most importantly, analyzed to make sure it is accepted while there is still time to react.

Let us know if you would like more information on this important, but very complex topic.

 

PS. In 2017, CMS will be replacing PQRS with the Merit-based Incentive Payment System (MIPS), as required by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). But many of us believe the quality portion of MIPS will look very much like PQRS!