Last month’s edition of this column ended by calling Fellows’ attention to a new Web-based tool developed by the ACS Division of Advocacy and Health Policy to assist them in avoiding significant penalties in Medicare physician payment. This new online tool was highlighted in an e-mail sent to Fellows on June 24, 2015.
Based on follow-up inquiries since received, I would like to delve deeper into the specifics of how to successfully participate in the Physician Quality Reporting System (PQRS) and hopefully assist Fellows in avoiding penalties of up to 9% in their Medicare physician payment in the year 2017 secondary to failure to successfully participate in the current law Medicare quality programs in the current calendar year of 2015.
Despite the much publicized, and laudable, permanent repeal of the Sustainable Growth Rate (SGR), current law quality programs are still in effect. Medicare oversees several programs that offer physicians incentives for successful participation and/or penalties for failure to nonparticipation. These programs include the PQRS, the Value-Based Payment Modifier (VM) and the Electronic Health Record (EHR) Incentive Program, also known as the “EHR Meaningful Use program.”
Calendar year 2014 was the last year that physicians could earn incentives for some of these programs. Failure to participate in the Medicare quality programs leads to the potential for penalties that are applied 2 years after the performance period. Penalties in 2015 already are being assessed based on how successfully physicians participated in 2013. Thus, performance in 2015 will impact payment in 2017. Specifically, failure to participate in the programs in 2015 could result in a total penalty of 9% applied in 2017.
The College has developed resources to assist Fellows in being successful reporters. For most Fellows, the options found in the Surgeon Specific Registry (SSR) will be applicable. The SSR, formerly known as the ACS Case Log system, allows surgeons to track their cases and outcomes in a convenient and confidential manner. The SSR can also be utilized to comply with the regulatory requirements of submitting PQRS data as they have been approved to provide PQRS registry-based reporting for 2015. Use of the SSR is offered free of charge to ACS surgeon members and is available to nonmember surgeons for an annual fee.
The SSR offers a total of three options for surgeons to utilize to participate in PQRS reporting. Those options are: 1) General Surgery Measures Group; 2) Individual Measure reporting, which includes options for surgical specialties; and 3) Trauma Measures Option through the SSR’s Qualified Clinical Data Registry (QCDR). The deadline for submitting calendar year 2015 patient information in the SSR is January 31, 2016. The SSR will submit the PQRS data to Centers for Medicare & Medicaid Services (CMS).
For those surgeons for whom it could be applicable, the General Surgery Measures Group option is perhaps the least onerous in its requirements. Surgeons need report on a minimum of 20 patients, at least 11 of whom must be Medicare Part B patients. Should this option be selected, ALL seven of the included measures along with all nine risk factor variables must be reported for each of the 20 patients.
Surgeons may also choose to report individual measures data through the SSR. Those choosing this option are required to report on nine measures in three National Quality Strategy (NQS) categories, called “Domains.” One of the measures selected must further be designated as a “cross-cutting measure,” for example the documentation of current medications in the medical record, medication reconciliation, advanced care plan, or tobacco-use screening and cessation, as mentioned above. However, individual measures data must be entered for at least 50% of the provider’s Medicare Part B patients in order to be successful using this option. In order to assist one in determining whether this option is suitable for reporting, I would refer Fellows to the ACS website, www.facs.org/quality-programs/ssr/pqrs/options for a more expansive list of the individual measures, their “domains,” and whether or not they are designated as “cross-cutting.”
The SSR also provides the opportunity to leverage measures applicable to trauma surgery for successful PQRS reporting via the 2015 PQRS Trauma QCDR., which allow providers to submit non-PQRS measures, for example, measures not contained in the approved measure set or a measure that may be in the set but has substantive differences in the manner in which it is reported by the QCDR. The SSR Trauma QCDR includes 10 non-PQRS measures and one PQRS measure in this reporting option. Those choosing this option must report on 9 of the 11 designated measures, including 2 outcomes measures across three of the NQS domains. Reports must be completed on 50% of the surgeon’s Medicare Part B patients that meet the measurement requirements. One can also view the complete list of measures included in the Trauma Measures Option at the ACS website referenced above.