From the Washington Office

From the Washington Office: Avoid Medicare Penalties



In the August edition of this column, I wrote at length about the requirement for surgeons to successfully report Medicare quality data in the current calendar year of 2015 in order to avoid Medicare payment penalties of up to 9 percent in 2017. It is absolutely imperative that surgeons take the time necessary to comply with the requirements of Medicare’s three current law quality programs in order to avoid the penalties associated with such.

Even though the MACRA legislation passed earlier this year mandates significant changes in the way Medicare payment updates to physicians are calculated, those changes will not go into effect until 2019. In the meantime, penalties remain in effect for Medicare’s three current law quality programs: PQRS (Physician Quality Reporting System), VBM (Value-Based Modifier) and EHR-MU (Electronic Health Record-Meaningful Use).

Dr. Patrick V. Bailey

Dr. Patrick V. Bailey

While it is certainly understandable that one could deem this requirement to be an unnecessary administrative burden taking time away from otherwise already busy and complex lives, successful compliance is not as daunting as one might imagine. Specifically, only one key action is necessary to avoid the Medicare penalties otherwise imposed by both PQRS and the VBM. That key action is compliance with the requirements of PQRS. Additionally, there are several resources available to you through the College’s website specifically designed to facilitate successful reporting in the most efficient way possible and minimize the time on task necessary to comply.

As was recently communicated to all Fellows in an e-mail communication from Dr. Hoyt, the ACS Surgeon Specific Registry (SSR) allows surgeons to track their cases and also facilitates compliance with the regulatory requirements of PQRS. Registration for the SSR can be found at:

The SSR allows surgeons to report on:

1) PQRS General Surgery Measures Group

2) PQRS Individual Measures

3) ACS SSR QCDR – Trauma Measures Option

Surgeons can utilize any of the three options to meet the requirements for PQRS compliance. A list of all the reportable measures available for each of the above can be found at:

For those surgeons for whom it could be applicable, the PQRS General Surgery Measure Group option is perhaps the least onerous. With this option, surgeons need to report on only twenty patients, eleven of whom must be Medicare Part B patients. Should this option be selected, Fellows need to be certain to complete the information by reporting on ALL seven of the included measures along with all nine risk factor variables for each of the twenty patients.

The deadline for submission of calendar year 2015 data into the SSR is January 31, 2016. The SSR will submit PQRS data on behalf of surgeons to Centers for Medicare and Medicaid Services (CMS).

The SSR is free of charge to ACS members.

Links to additional resources which provide further information include:

1) Glossary of Terms:

2) “How to Avoid Medicare Penalties” – summary document:

3) Step by Step Flowchart of Participation in Medicare Quality Programs:

As always, ACS staff in both the Washington and Chicago offices are available to answer questions and assist members in participating in the 2015 PQRS program:

General PQRS questions: ACS Division of Advocacy and Health Policy, 202/337-6701 or

Specific SSR questions: ACS Division of Research and Optimal Patient Care, 312/202-5000 or

In closing, I will again highly encourage all Fellows to invest the time necessary to successfully comply with the PQRS requirement through the SSR and thereby avoid penalties of up to 9 percent in their 2017 Medicare payment.

Until next month...

Dr. Bailey is a pediatric surgeon and Medical Director, Advocacy for the Division of Advocacy and Health Policy in the ACS offices in Washington.

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