PHYSICAN QUALITY REPORTING SYSTEM (PQRS)/QUALIFIED CLINICAL DATA REGISTRY (QCDR) FAQ

QCDR FAQ's of the Week

Frequently Asked Questions About PQRS QCDR

What is the Physician Quality Reporting System (PQRS)?

PQRS is a voluntary reporting program that uses a combination of incentive payments and payment adjustments to promote reporting of quality information by eligible professionals (EPs). Under PQRS, covered professional services are those paid under or based on the Medicare Physician Fee Schedule (PFS). Anesthesiologists whose professional services are paid under the Medicare PFS are considered EPs. To the extent that EPs are providing services which get paid under or based on the PFS, those services are eligible for PQRS incentive payments and/or payment adjustments.

2014 was the last year that PQRS incentives were available to satisfactory reporters.Practices that satisfactorily reported or satisfactorily participated in PQRS in 2014 should receive their incentives in late 2015.

In 2015, non-participation in PQRS or EPs who do not satisfactorily report (via claims, “traditional” qualified registry, Electronic Health Record, or the Group Practice Reporting Option reporting mechanisms) or satisfactorily participate (via the Qualified Clinical Data Registry reporting mechanism) are subject to a 2.0% payment adjustment on their covered professional services in 2017. Unlike previous years, there are no incentives for participating in PQRS in 2015 and beyond.

Why is participation in PQRS important? How does it apply to the Value-Based Payment Modifier(VM)?

For the 2015 reporting period, PQRS includes a payment adjustment of 2% for non-participation or failure to satisfactory report or satisfactorily participate on your covered professional services in 2017. There is an interval between the end of the PQRS reporting period and the monetary consequences to EPs. Payment adjustments and the Value-Based Payment Modifier (VM) take effect one year after the close of the PQRS reporting period, so 2015 PQRS reporting affects covered professional service payments in 2017.

For the VM, practices of 2-9 EPs and solo practitioners who opt not to report PQRS or fail to satisfactorily report or satisfactorily participate risk a -2% modifier while groups of 10 EPs risk a -4% modifier via the Value-Based Payment Modifier (VM).

For the VM, EPs and practices that satisfactorily reporting or satisfactorily participating in PQRS in 2015 are subject to the quality-tiering category for the VM. In this category, practices demonstrating low cost but high quality, determined by a set of cost, resource and other PQRS measures, may see a positive modifier. Practices providing low quality and high cost care are subject to a negative modifier. For others, a neutral modifier will apply.

For the VM, EPs and practices that satisfactorily reporting or satisfactorily participating in PQRS in 2015 are subject to the quality-tiering category for the VM. In this category, practices demonstrating low cost but high quality, determined by a set of cost, resource and other PQRS measures, may see a positive modifier. Practices providing low quality and high cost care are subject to a negative modifier. For others, a neutral modifier will apply.

For the VM groups of ten (10) or more EPs with the quality-tiering category for the VM are eligible for an upward, downward or neutral modifier for 2017.

How do I participate in the 2015 Physician Quality Reporting System (PQRS)?

Individual Eligible Professionals (EPs) can participate using any of the below reporting methods:

Note that the 2014 Physician Fee Schedule (PFS) Final Rule finalized an additional method for individual PQRS reporting—the QCDR. A QCDR is a CMS-approved entity, such as a registry, certification board or collaborative that collects medical and/or clinical data for the purpose of patient and disease tracking to foster improvement in the quality of care furnished to patients. The data submitted to CMS via a QCDR covers quality measures cross multiple payers and is not limited to Medicare beneficiaries. A QCDR is different from a qualified registry in that it is not limited to current measures within PQRS. In 2015, a QCDR may include a maximum of 30 non-PQRS measures. This option is different from a “traditional” qualified registry in that each QCDR has flexibility to develop measures that will best achieve the goal of improving the quality of care furnished by EPs.

The Anesthesia Quality Institute (AQI) National Anesthesia Clinical Outcomes Registry (NACOR) is a certified QCDR. Please visit ASA QCDR for more information on reporting via AQI.

How many measures do I need to report?

Regardless of the reporting mechanism, EPs are generally required to report nine (9) measures across three (3) National Quality Strategy Domains. Yet each reporting mechanism includes different criteria for satisfactorily reporting or satisfactorily participating. The EP may choose which measures to report so ling as s/he meets the criteria for reporting.

For satisfactorily reporting via the Qualified Clinical Data Registry (QCDR) reporting mechanism:

  • Report at least nine (9) measures available for reporting under a QCDR covering at least three (3) NQS domains.
  • Report each measure for at least 50 percent of the EP's patients (Medicare AND non-Medicare)
  • Report on at least two (2) outcome measures OR if two outcomes measures are not available, report on at least one (1) outcome measure and at least 1 of the following types of measures-resource use, patient experience of care, efficiency/appropriate use, or patient safety.
  • NOTE: If you are participating via the CMS-Approved ASA QCDR, you must report on two outcome measures.

For satisfactorily reporting via claims, "traditional" qualified clinical registry or other reporting mechanisms, please visit the ASA Quality and Regulatory Affairs PQRS webpage.

What are the six NQS Domains?

All PQRS and non-PQRS QCDR measures are assigned one of the six NQS domains. In 2015, EPs are required to report measures across three NQS domains. The domains include:

  1. Patient Safety
  2. Person and Caregiver-Centered Experience and Outcomes
  3. Communication and Care Coordination
  4. Clinical Care
  5. Population Health
  6. Efficiency and Cost Reduction

For other reporting options such as EHR or the Group Practice Reporting Option (GPRO), please visit the CMS PQRS webpage or visit ASA Quality and Regulatory Affairs.

How much is my incentive payment?

2014 was the last year that PQRS incentives were available to satisfactory reporters. Practices that are satisfactorily reporting or satisfactorily participating in PQRS in 2015 will be placed in the quality-tiering category for the VM. In this category, practices demonstrating low cost but high quality, determined by a set of cost, resource and other PQRS measures, may see a positive modifier. Practices providing low quality and high cost care are subject to a negative modifier.

Groups of ten (10) or more EPs within the quality-tiering category for the VM are eligible for an upward, downward, or neutral modifier in 2017. Groups if 2-9 EPs are eligible for an upward or neutral modifier for 2017.

Am I subject to a penalty if I do not participate in PQRS?

Yes (if your covered professional services are based upon or paid under the Medicare Physician Fee Schedule). If an eligible professional (EP) does not participate in PQRS during the 2015 reporting period, s/he may receive a PQRS payment adjustment of 2% on the covered professional services in 2017.

Practices of 2-9 EPs and solo practitioners who opt not to report PQRS or fail to satisfactorily report or satisfactorily participate risk a -2% modifier while groups of 10 EPs or more will be assessed a -4% modifier via the Value-Based Payment Modifier (VM).

EPS and practices that satisfactorily report or satisfactorily participate in PQRS in 2015 will be placed in the quality-tiering category for the VM. In this category, practices demonstrating low cost but high quality, determined by a set of cost, resource and other PQRS measures, may see a positive modifier. Practices providing low quality and high cost care are subject to a negative modifier.

Groups of ten (10) or more EPs within the quality-tiering category for the VM are eligible for an upward, downward, or neutral modifier in 2017. Groups of 2-9 EPs are eligible for an upward or neutral modifier for 2017.

What are cross-cutting measures and do I have to report on cross-cutting measures?

Reporting of cross-cutting measures is required for claims and the "Traditional" qualified registry reporting mechanism. Reporting a cross-cutting measure is NOT a requirement for the QCDR reporting option. For additional information on cross-cutting measure requirements for the claims and the "Traditional" qualified registry reporting mechanisms, please visit the ASA Quality and Regulatory Affairs PQRS website.

How do I register to participate in PQRS?

Individual eligible professionals (EPs) do not need to sign-up or pre-register in order to participate in PQRS. However, practices participating in and submitting measures via claims, registry, Electronic Health Record (EHR), Qualified Clinical Data Registry (QCDR) or via the GPRO option should visit the PQRS website for additional information and contact relevant vendors for reporting PQRS measures.

Review these QCDR Steps to begin using NACOR for PQRS reporting.

How are data submitted for the NACOR non-PQRS measures?

Non-PQRS data is submitted 2 ways:

Non-PQRS Measures 6-8 can be reported using a designated Category II CPT code. The remaining non-PQRS measures require an Outcome Value (A, B, C, D).

How are data submitted for the NACOR PQRS measures?

Data are submitted by a claims-based approach of coding Cat II CPT codes on the billing record.

When is the registration deadline for 2015 reporting PQRS through AQI?

There is not necessarily a registration deadline. AQI can work with practices that are collecting proper data into the later part of the year though the sooner a practice begins working with AQI to submit data the better off the practice will be. When a practice begins submitting data to AQI they have access to reports that are updated monthly to ensure that the proper data will be submitted at the end of the year. This being said, it is easier to correct early on in the year than it would be at the end of the year.

Are there any webinars which provide answers to PQRS-related questions?

In the future, AQI is hoping to set up monthly webinars to educate and answer questions any participants may have. Please look on our website for other documents and posted webinars that assist in answering PQRS-related questions.

Why use QCDR?

The benefits for using QCDR include the following important factors:

  • Greater potential to meet the reporting requirement of 9 measures across 3 National Quality Strategy domains, particularly with increasing strict requirements for claims-based reporting.
  • Meeting PQRS requirements by participating in a Qualified Clinical Data REgistry offer more relevant measures that help achieve meaningful quality improvement.
Do the new PQRS and AQI measures have to start submission on January 1, 2015? If not, what is an expectable timeframe for us to begin measuring them?

AQI recommends submitting your data early in 2015 to ensure that your practice will be successful in reporting 9 measures to CMS. When reporting through the ASA QCDR your practice will have access to monthly reports that will gauge your practice's performance on the measures.

Do we have to track or report on all available QCDR measures?

No, you just have to meet the criteria for the PQRS QCDR Reporting Mechanism.

Does the MAV apply to the QCDR reporting option?

No.

Does AQI/NACOR send out any type of benchmarking data or trending reports on the data for claims-based reporting?

For EPs participating in the QCDR reporting mechanism, the QCDR is required to provide you with information on at least a quarterly basis. Please contact AQI/NACOR for further information on feedback reports.

If I already participate in submitting data to AQI, do I still need an agreement with ASA?

Yes, you must sign a purchase agreement with ASA outlining the memberships and QCDR services you are purchasing for your practice. There is also an AQI QCDR agreement authorizing AQI to send your data to CMS.

Note: Being a member of AQI strictly isn't enough. Please view the AQI QCDR Steps to ensure you are properly signed up to report via the QCDR.

Our professional corporation has one employee who is not an ASA member. Do we need to pay $1,000 for him or $295? Also, occasionally we use independent contractors as locum tenens physicians. We bill for these folks under our tax ID number. DOes that mean we would need to pay for them if they are not ASA members? Would that be $1,000 or $295?

If you are reporting their data through the QCDR, you will need to pay for either ASA membership or AQI membership for every physician provider. If you purchase ASA membership, there is no additional fee for QCDR reporting. If you purchase the AQI membership($1,000), you must also purchase the ASA QCDR for $295.

Please visit the CMS webpages listed below for additional resources on PQRS reporting:


©2015 AQI

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