The PQRS Deadline is Almost Here
It’s critical to meet the deadline in order to avoid penalties—and it’s not too late to begin reporting for 2013 By Gina Zinanni
In an effort to avoid the Physician Quality Reporting System (PQRS) penalty placed on providers by the Centers for Medicare and Medicaid Services (CMS) beginning in January 2015, practices are scrambling to meet the 2013 reporting deadline. Until now PQRS was considered an incentive program only, with many providers choosing not to participate. Beginning in 2015, a Medicare payment adjustment will apply to providers who do not satisfactorily submit quality measures for services provided during the reporting period.
Professional Business Consultants (PBC) recommends that all eligible providers begin PQRS reporting if they have not already done so. As our nation’s health care system transitions from fee-for-service to pay-for-performance, the penalties could skyrocket for providers who do not participate in these programs.
It may not be too late to begin reporting 2013 data. The deadline to report 2013 data to CMS is Feb. 24, 2014.
PQRS
It is a common misconception that practices that have reported Clinical Quality Measures (CQM) via Meaningful Use (MU) attestation have successfully satisfied the PQRS reporting requirement. This is not the case. Meaningful Use and PQRS are two separate programs with their own rules and requirements. Although both programs are administered by CMS, there is no alignment between the two.
There are currently four ways to report PQRS measures:
- To CMS via Medicare Part B claims.
- To a qualified Physician Quality Reporting Registry.
- To CMS via a qualified EHR system.
- To a qualified Physicians Quality Reporting Data submissions vendor.
If you have an electronic health record (EHR), you may wish to contact your vendor and ask about the PQRS reporting services they provide. If you are not able to submit via an EHR and plan to use a registry, you must secure that relationship immediately. A list of 2013 Participating Registry Vendors can be found on the CMS website. Don’t delay. The incentives are running out and the penalties are kicking in.
Physicians who satisfactorily report 2013 data are still eligible for a 0.5% incentive on covered Medicare Part B services provided during that reporting period. For physicians who fail to satisfactorily report PQRS data for the 2013 reporting period, a 1.5% fee schedule adjustment will be placed on all covered Medicare Part B services beginning in 2015.
GPRO
The Group Practice Reporting Option (GPRO) allows group practices to report PQRS as a group instead of as individuals. Larger groups should find it easier to meet PQRS measures under the GPRO option. For example, if a patient sees only one provider in the group and a PQRS measure is captured, all providers in the group get credit. To qualify under GPRO a group must have two or more eligible providers billing Medicare under the same tax identification number (TIN).
Currently, groups of 2-99 eligible providers may elect to report PQRS as individuals, or as a group under GPRO. Beginning in 2013 all groups of 100+ eligible providers must report under GPRO to avoid the Value Based Modifier penalty of an additional 1%.
GPRO requirements and highlights for the Jan. 1, 2013-Dec. 31, 2013, reporting period are:
2-24 Eligible Providers
Must report via registry.
Eligible for the standard PQRS 0.5% incentive for 2013.
Subject to the 2015 PQRS penalty of 1.5% in 2015 for failure to report.
Not yet subject to the Value Based Modifier penalty.
Must have registered/self-nominated by Oct. 15, 2013.
25-99 Eligible Providers
Must report via GPRO Web Interface.
Eligible for the standard PQRS 0.5% incentive for 2013.
Subject to the 2015 PQRS penalty of 1.5% in 2015 for failure to report.
Not yet subject to the Value Based Modifier penalty.
Must have registered/self-nominated by Oct. 15, 2013
100+ Eligible Providers
Must report via GPRO Web Interface.
Eligible for the standard PQRS 0.5% incentive for 2013.
Subject to the 2015 PQRS penalty of 1.5% in 2015 for failure to report.
Subject to an additional 1% Value Based Modifier penalty in 2015 for failure to report via GPRO.
Must have registered/self-nominated by Oct. 15, 2013.
VBM
Medicare introduced the Value Based Modifier (VBM) for the 2013 reporting year. In 2013, all groups of 100 or more providers were subject to the VBM. The program is expected to expand every year. By 2017, all providers in any size group will be subject to the VBM. The VBM program introduces a new 1% penalty. The only way to avoid this penalty is to submit PQRS data to CMS using one of the GPRO reporting methods. For the 2013 reporting year, the Registry Option and the Web Based Tool Interface option are the only two ways allowable to submit to the GPRO.
Even though it is confusing, it’s not too late to report PQRS for the 2013 reporting year. Although the Oct. 15 deadline for group registration/self-nomination has expired, physicians can still contact registries to get involved. Lists of registeries can be found on the CMS website at www.cms.gov. Other helpful documents can be found there as well. All eligible providers should make an effort to participate as soon as possible if they haven’t already done so. Although the incentives are decreasing, the penalties will continue to increase. Implement now to protect your reimbursement in the future and keep your practice viable.
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