Whether one of your resolutions in 2015 was to spend more time on quality improvement or simply to take steps to make sure your income stays steady through this tumultuous time in healthcare, you’re lucky that time hasn’t run out for you to meet those resolutions just yet.
Taking action now is very important for physicians who regularly see Medicare patients because reporting 2015 PQRS data to the Centers for Medicare and Medicaid Services (CMS) is the only way to avoid two negative payment adjustments that would impact your Medicare Part B reimbursements in CY 2017:
- 2.0% negative adjustment for PQRS
- 2.0%-4.0% negative adjustment for the Value-Based Payment Modifier
It is important to note that the 2.0%-4.0% swing in penalties associated with the Value-Based Payment Modifier is related to practice size. Solo physicians and groups with 2-9 eligible professionals are subject to the 2.0% penalty if they do not report PQRS for CY 2015. The 4.0% penalty would be applied to groups with 10 or more eligible professionals.
No one likes losing up to 6% of their income, especially when that money is taken away based on something that happened (or didn’t happen) two years prior. Unfortunately, CMS is known for this two-year lag in payment adjustments and physicians are stuck making sure they report data appropriately and in time to avoid penalties down the road. While there are multiple ways to participate in PQRS if one gets started earlier in the year, the easiest mechanism for late starters is reporting PQRS Measures Groups to CMS through a PQRS Qualified Registry.
Since the deadline for qualified registries to report PQRS data to CMS is not until March 31, 2016, physicians who have access to data from the 2015 year—either through their billing provider or their EHR—may still be able to validate this data and send it to a registry prior to the deadline. In addition, PQRS Measures Groups are the easiest way to meet reporting requirements this late in the game because physicians are only required to report data for a 20 patient sample, for each measure in the group. The following steps will maximize your chance of successful participation in PQRS for the 2015 year:
- Identify a PQRS Qualified Registry that reports measures applicable to your specialty that is still taking new customers for the 2015 reporting year.
- Download the CMS PQRS Measures Groups documentation and determine which Measures Group is applicable to your patient population.
- Review your available data sources (billing systems, EHR systems, etc.) and determine whether data is available for encounters that occurred between January 1, 2015 and December 31, 2015.
- Contact the Qualified Registry of your choice to find out how they receive data from physicians for PQRS, and if needed, reach out to your EHR vendor or billing system vendor to make sure you can access the data in the necessary format.
After you take the steps needed for reporting PQRS in 2015, be sure to keep your eyes out for information on how to participate in PQRS for CY 2016 year as well. Unfortunately the payment penalties will continue to add up, but at least you’ll have more of a head start than last year.