How Does the EHR PQRS Incentive Program Affect ENTs?
The EHR PQRS incentive program is a part of the overall EHR incentive programs and has been in force for close to a decade, having started its life as the Physician Quality Reporting Initiative back in 2007. For otolaryngologists, the reality of this mandatory reporting program should be apparent, especially as the CMS, through the Affordable Care Act (ACA), has opted to enforce compliance through the introduction of a penalty for qualifying EPs that do not meet the reporting threshold laid out in the program specifications.
In the past, there have been a number of CMS programs that have been postponed such as the implementation of ICD-10. Nevertheless, it’s important to know that the implementation of the PQRS reporting program will not be postponed, especially the negative adjustments that the CMS has promised to implement beginning this year, 2015.
This negative adjustment, which is pegged at 1.5% in 2015, will rise to 2% in 2016, impacting ENT’s allowable Medicare payments over the two years. The crucial thing to note, however, is that the penalty levied in 2015 will be based on reporting data collected in 2013, which means that ENTs that did not report satisfactorily through the months of 2013 will lose 1.5% of their Medicare payments in 2015.
To satisfactorily report your PQRS measures, another aspect that will affect you is the reporting options you use. The CMS PQRS standards are explicit in how they require EPs to report the measures. They are also very specific in terms of the measures they want you to report. This has been a challenge for many ENTs as there has been a measure of confusion with regards to this. For instance, just because you are reporting measures from one of the EHR programs does not mean they will necessarily meet the CMS PQRS reporting standards.
This is because the different Medicare and Medicaid programs may have similar measures but they aren’t an exact match. In addition, the method or channel you use to report your measures could be negatively affecting how you report. The CMS has prescribed four channels to do your reporting through, which are: through your Medicare Part B claims, through a qualified PQRS registry, direct EHR using CEHRT (Certified EHR Technology), CEHRT via data submission vendor and a qualified clinical data registry (QCDR).
These may be options but they have also proven to be a source of confusion for many an ENT owing to the discreet nature of each channel and how it should be used. Moreover, some practices have found themselves using technology that isn’t EHR certified or does not have an updated PQRS module, and as a result have been “reporting” measures but these measures have either not been reflected in the main registry or have been incorrectly reported.
Regardless of which reporting channel you use, it’s up to you to ensure your reporting complies with the CMS reporting standards and not leave anything to assumption. You must find out from the CMS whether your reporting is in line with its standards rather than letting things run on idly and you aren’t sure you’re in the clear.
Choosing Measures to Report
Another sticking point otolaryngologists need to look out for is the measures they choose to report on. With 255 measures to choose from spread across a number of measures groups, you need to know which measures will most closely apply to your ENT practice. The danger of picking the wrong measures is that you won’t have enough patients coming in with those conditions for you to adequately report on them.
Finding out which measures apply the most to the majority of your patients is the key to having a set of measures you can report on sufficiently and consistently. Once you know which measures apply to your practice specialty, make sure you report the minimum number of one measures group or three individual measures for a minimum of 50% and 80% of your patients respectively.
The PQRS program is here to stay and for ENTs who want to avoid negative adjustments on the allowable Medicare payments, it’s imperative to ensure the minimum threshold of reporting is met and exceeded. With penalties set to rise further in 2016 there’s no telling whether this will turn out to be the trend going into the future and whether the CMS will introduce more punitive measures for those who do not comply.