CMS Physician Fee Schedule Rule: Physician Quality Reporting System Changes

On Wednesday, November 27, the Centers for Medicare and Medicaid Services (CMS) released its 2014 Physician Fee Schedule (PFS) Final Rule for calendar year 2014. In addition to payment policies, the rule outlines changes in the Physician Quality Reporting System (PQRS), the Medicare Electronic Health Record (EHR) Incentive Program, and the Physician Compare website. The implementation of the Value-Based Payment Modifier Program (VBMP) is also discussed. CMS will accept comments on the Final Rule through January 27, 2014. ISIS is reviewing the document and will be developing comments to submit to CMS in the coming weeks. Brief descriptions and some highlights of changes made to these programs are included HERE.

PQRS: The PQRS is a quality reporting program that has been using incentive payments to encourage eligible professionals (EPs) to report on specific quality measures to both ensure that patients receive the proper care at the proper time and quantify how often the providers meet a particular quality metric. Providers can report via Medicare Part B claims, a physician quality reporting registry, a qualified EHR product, or a qualified data submission vendor. With feedback reports provided by CMS, EPs may compare their performance with their peers. In 2015, PQRS will begin to use payment adjustments to further encourage reporting.

Incentive Payments and Payment Adjustments: Individual EPs who meet the criteria for satisfactory submission of PQRS quality measures data via one of the accepted reporting mechanisms for services furnished during the 2013 and 2014 reporting periods will qualify to earn an incentive payment equal to 0.5% of their total estimated Medicare Part B PFS allowed charges for covered professional services furnished during that same reporting period. Beginning in 2015, the program applies a -1.5% payment adjustment to EPs who did not satisfactorily report data on quality measures for covered professional services during the 2013 PQRS program year. The negative payment adjustment will increase to 2% in 2016 for EPs who do not satisfactorily report in the 2014 PQRS program year.

• Changes to Measures and Reporting Criteria of Interest to ISIS Members:

• Across the claims, registry, and EHR reporting methods, the new requirements to achieve the "satisfactorily reporting" incentive are: 9 measures across 3 National Quality Strategy domains. The goal of these requirements is to allow eligible professionals to avoid the payment adjustment described above.
• The Back Pain Measures Group will be reportable via Registry only.

• Two New PQRS Reporting Options:

• Certified Survey Vendors will be available to group practices of 25 or more EPs which participate under the Group Practice Reporting Option (GPRO), and which agree to report Clinician and Group Consumer Assessment of Healthcare Providers and Systems (CG-CAHPS) data. The data collected will be submitted by the vendor and the results eventually will be posted on the Physician Compare website.
• Qualified Clinical Data Registries (QCDR) are CMS-approved entities that have self-nominated and completed a qualification process to serve as QCDRs and meet certain data and program requirements. The deadline for a QCDR to self-nominate is January 31, 2014 with a March 31 deadline to submit measures information.

Medicare EHR Incentive Program: This program provides incentive payments to eligible professionals and facilities as they implement certified electronic health record technology and demonstrate meaningful use of the EHR. The incentive payment is 75% of a provider’s Medicare allowed charges, up to $44,000 over five consecutive years, and there is an additional incentive for those who practice in a Health Professional Shortage Area. EPs must begin their EHR process by 2014 to receive EHR incentive payments; the final incentive payment year is 2016. In 2015, payment adjustments of 1% per year will begin for providers who are eligible for the Medicare EHR Incentive Program but decided not to participate; depending on the total number of Medicare EPs who participate after 2018, the maximum cumulative negative payment adjustment is 5%. Meaningful use of the EHR technology must be demonstrated in order to receive the incentive. Specific requirements relative to the reporting methods and reporting periods of Clinical Quality Measures (CQM) are outlined in the final rule.

Physician Compare website: The Physician Compare website allows consumers to search for physicians and other healthcare professionals who provide Medicare services. At this time, the site provides information on providers’ names, addresses, contact information, specialties, clinical training, gender, languages spoken, affiliated hospitals, and Medicare payment information for both individual practitioners and group practices. Physician Compare includes information from providers who satisfactorily participate in CMS quality programs, including PQRS, the eRx Incentive Program, the EHR Incentive Program, the Medicare Shared Savings Program, and the Value-based Payment Modifier. A full redesign of the website was launched in 2013 to implement improvements to the underlying database as well as an Intelligent Search feature; the changes addressed improving functionality and usability of the website for consumers.

Groups:

• The first set of measure data will be posted on Physician Compare in early 2014, reflecting data collected no earlier than program year 2012 from the PQRS GPRO measures for groups of all sizes.
• It is anticipated that only data collected in 2013 under the GPRO Diabetes Mellitus (DM) and Coronary Artery Disease (CAD) measures and composites will be publicly reported in late 2014.
• 2014 data will be publicly reported in 2015, on all measures collected through GPRO for groups of all sizes; providers will have a 30-day preview period of their data.CMS states that a detailed timeline for the preview will be provided in advance of its start.
• A quality programs section has been added to each group practice profile page to indicate satisfactory reporting in the GPRO or e-prescribing under the eRx Incentive Program.

Individuals:

• PQRS individual measure data collected in 2014 will be publicly reported in 2015 for individual PQRS quality measures, if technically feasible. The individual PQRS quality measures will be in line with those measures reported by groups in GPRO.

Value-Based Payment Modifier Program (VBPM): The VBPM Program will provide comparative performance information to physicians as part of Medicare's efforts to improve the quality and efficiency of medical care. By providing meaningful and actionable information to physicians so they can improve the care they deliver, CMS is moving toward physician reimbursement that rewards value rather than volume. Currently the program applies only to physicians in large groups, but by 2017 all physicians who participate in Medicare FFS will be affected by the value modifier.

• In 2015, physicians of groups of 100 or more EPs who submit claims to Medicare will be subject to the VBPM, based on their calendar year 2013 performance. Groups that fail to report will be subject to a -1% value modifier adjustment to their 2015 payment.
• The VBPM adjustment is in addition to the PQRS payment adjustment.

CMS will accept comments on the Final Rule through January 27, 2014. ISIS is reviewing the document and will be developing comments to submit to CMS in the coming weeks.

The entire rule can be found at: http://www.ofr.gov/OFRUpload/OFRData/2013-28696_PI.pdf