This month, I would like to call Fellows’ attention to some pending changes in the quality measures landscape, which can impact Medicare payment. By the time this issue goes to press, all Fellows should have received e-mail from ACS leadership referencing the document, “How to Avoid Medicare Penalties” available at . This document highlights the penalties Fellows might face if they do not participate in the various Medicare quality incentive programs. It also summarizes an excellent article in the September issue of the ACS Bulletin (Vol. 99, No. 9, pp. 28-32), “The benefits of PQRS participation and what the College is doing on your behalf,” by Charles D. Mabry, MD, FACS, Chair, ACS Health Policy Advisory Council (HPAC) and Sana Z. Gokak, MPH, a member of the Quality Affairs team here in the Washington office.
As most are acutely aware, the last few years have seen a change in the quantity and types of data collected by the Centers for Medicare & Medicaid Services (CMS). As part of this change, a shift has been made from the collection of administrative data toward collection of clinical data. Medicare payment has begun to shift from pay for reporting with the Physician Quality Reporting System (PQRS) program to pay for performance with the Value-Based Payment Modifier (VM).
The current calendar year of 2014 is the last year in which physicians may earn PQRS and Electronic Health Record (EHR) Incentive Program bonus payments based on their participation in CMS programs. Based on their record from 2014 of either successful participation or nonparticipation in the PQRS, VM, and EHR programs, surgeons’ Medicare payment could be impacted by up to a –6% in 2016. Whether or not providers participate in PQRS will also be indicated on the PHYSICIAN COMPARE website. The deadline for submission of data to CMS for 2014 is Jan. 31, 2015.
Physicians and other providers must submit data to the PQRS program in order to have such indicated on the PHYSICIAN COMPARE website. In addition, the data submitted through PQRS will be utilized in future years to increase or decrease fee-for-service (FFS) payments based on the VM. The VM payment adjustment will begin in 2015, but the data utilized for the 2015 adjustment will be based on 2013 performance. Payment adjustment will apply to all physicians by 2017, based on their 2015 data. For most Medicare incentive programs, penalties will apply to the physician’s Medicare payments 2 years after their performance in the programs.
Providing data to PQRS is thus the key and may be submitted by physician group practices via the Group Practice Reporting Option (GPRO) or individually via claims, EHRs, or Qualified Registries, or Qualified Clinical Data Registries (QCDR). The ACS has two registries available to assist Fellows to be successful participants in the submission of data for the PQRS program. These are the Surgeon Specific Registry (SSR) Qualified Registry and the Metabolic and Bariatric Surgery Accreditation and Quality Improvement Program (MBSAQIP) QCDR.
Many surgeons are familiar with the SSR as the ACS Case Log system whereby data was collected for the American Board of Surgery Maintenance of Certification program. Through this online program, surgeons can report on either the Perioperative Measures Group or the General Surgery Measures Group. To be successful for 2014, and thus avoid a penalty applied to payment in 2016, reports on 20 majority Medicare patients for either of the two measures groups seen during calendar year 2014 should be submitted to the SSR by Jan, 31, 2015. The SSR will submit the PQRS data to CMS.
The SSR is available at no cost to ACS members. For those not familiar with the Case Log, they may register for same at https://www.facs.org/quality-programs/ssr. Surgeons must consent to and sign up for PQRS reporting through the SSR if they want their data submitted to CMS.
In sum, it is frequently said that the only constant is change. Though the administrative requirements are much different than they were in the past, the ACS is working hard to make resources available to assist members in being successful in the ever-changing health care environment. The following ACS staff members are available to answer questions and assist members in participating in the 2014 PQRS program, EHR Incentive Program, the VM and to facilitate enrollment in the SSR and MBSAQIP:
• General PQRS, EHR, and VM questions: Sana Gokak, ACS Division of Advocacy and Health Policy, 202/337-2701 or firstname.lastname@example.org.
• Information on the SSR: Bianca Reyes, ACS Division of Research and Optimal Patient Care, 312/202-5000 or email@example.com.