November 15, 2005

 

Medicare’s Physician Voluntary Reporting Program (PVRP)
CMS launches program for the voluntary reporting of certain quality indicators

CMS has announced that starting on January 1, 2006, interested physicians may participate in a voluntary program of reporting on 36 performance measures. The intent of the Physician Voluntary Reporting Program (PVRP) is to “initiate the process by which physicians who choose to participate would begin reporting quality data and be able to receive feedback on their performance, as well as to provide input on how quality reporting can be improved and made less burdensome.”

ASA members should note that, as currently designed, the PVRP provides no additional payment or reward for reporting under the program. While future legislative enactments could change this situation, current participation is best viewed as an opportunity to get a “head start” on implementing systems and practices for the reporting of future quality measures, as government and private payers head increasingly in this direction.

Anesthesiology Performance Measures. In a good faith response to early requests from CMS for active participation by all medical specialty societies in the development of this demonstration project, ASA was very active in working to achieve the adoption of several appropriate performance measures for anesthesiology and pain medicine. (Similar critical care measures also are under development currently.) One of the measures that we submitted to the Agency – timely administration of pre-operative antibiotic prophylaxis – is among the final list of 36 measures adopted. Where feasible and appropriate, anesthesiologists and other physicians may begin using this measure as of the New Year.

At the same time, ASA was disappointed that the other two measures that we refined extensively based on many discussions with CMS staff -- maintenance of normothermia and comprehensive planning for chronic pain management - - were not approved for inclusion in this initial CMS demonstration project. Many other medical specialties were dealt a similar hand by CMS on other individual measures, also without explanation, and there exists confusion and concern about these developments.

The failure to include additional “starter set” anesthesiology measures in the CMS pilot project is especially troubling because the current pilot could well serve as the basis for legislation that could soon emerge from Congress on so-called “Pay-for-Performance” (P4P). As described under the November 1 st alert on the home page, the Senate Budget Reconciliation bill, for example, provides for both a 1% positive update for Medicare payments to physicians and a largely undefined performance measures reporting requirement. The correction to the fee schedule update, which would otherwise be negative 4.4%, is of the utmost importance to all of medicine – but it must not be tied to any untested quality reporting system, especially one for which only a few pieces of the necessary infrastructure, including a sufficient number of acceptable measures, exist. ASA will continue to actively lobby to bring our concerns to the attention of Congress, but in the mean time, we are committed to ensuring that any measures applicable to anesthesiology, in any Federal program, be developed by and for the specialty. ASA cannot and will not accept the Federal government dictating measures to anesthesiology on its own, as some of the bills before Congress would do. Any such activity in this arena needs to be specialty-driven and directed.

How the PVRP Works. The (PVRP)’s most important feature – aside from its voluntary nature – is the use of claims data for quality reporting. Other physician performance reporting systems rely on retrospective chart reviews, at a much greater cost and burden. CMS has created new 5-digit codes starting with the letter “G” that can be included in the claim submitted to Medicare just like CPT® codes. Eligible patients are identified through either CPT® procedure codes or ICD-9 diagnostic codes. The PVRP is designed to test the validity of this “G-code,” administrative data approach.

Below are the CMS specifications and instructions for reporting antibiotic prophylaxis (note that the measure’s applicability to anesthesiologists is stated under “Instructions”). Other measures of potential interest to our specialty include annual assessment of function and pain in symptomatic osteoarthritis and pre-operative beta blocker for patient with isolated coronary artery bypass graft.

For the specifications for all 36 measures and other information on the PVRP, please see CMS’ web page at http://www.cms.hhs.gov/quality/pfqi.asp.

Measure: Antibiotic prophylaxis in surgical patient

Numerator:

G8152 : Patient documented to have received antibiotic prophylaxis one hour prior to incision time (two hours for vancomycin)

G8153 : Patient not documented to have received antibiotic prophylaxis one hour prior to incision time (two hours for vancomycin)

G8154 : Clinician documented that patient was not an eligible candidate for antibiotic prophylaxis one hour prior to incision time (two hours for vancomycin) measure

Denominator:

Patients with selected surgical procedures as listed:

Musculoskeletal: 27130, 27125, 27138, 27437, 27445, 27446

Cardiovascular System: 33300 33305 33400 33401 33403 33404 33405 33406 33410 33411 33412 33413 33414 33415 33416 33417 33420 33422 33425 33426 33427 33430 33460 33463 33464 33465 33468 33470 33471 33472 33474 33475 33476 33478 33496 33510 33511 33512 33513 33514 33516 33517 33518 33519 33521 33522 33523 33530 33533 33534 33535 33536 33545 33560 33600 33602 33608 33610 33611 33612 33615 33617 33619 33641 33645 33647 33660 33665 33670 33681 33684 33688 33692 33694 33697 33702 33710 33720 33722 33730 33732 33735 33736 33737 33770 33771 33774 33775 33776 33777 33778 33779 33780 33781 33786 33813 33814 33875 33877 33918 33919 33920 33924 33999 34520 34830 34831 34832 35081 35082 35091 35092 35102 35103 35111 35112 35121 35122 35131 35132 35141 35142 35151 35152 35256 35286 35331 35341 35351 35355 35361 35363 35371 35372 35381 35516 35518 35521 35522 35525 35531 35533 35536 35541 35546 35548 35549 35551 35556 35558 35563 35565 35566 35571 35583 35585 35587 35600 35616 35621 35623 35631 35636 35641 35646 35647 35650 35651 35654 35656 35661 35665 35666 35671 35686 35879 35881 35903 35907 37500 37700 37720 37730 37735 37760 37765 37766 37780 37785 37788 37791 92992 92993 93580 93581

Hemic and Lymphatic Systems: 38082 38103

Digestive System: 44025 44110 44111 44120 44121 44125 44130 44139 44140 44141 44143 44144 44145 44146 44147 44150 44151 44152 44153 44155 44156 44160 44204 44205 44206 44207 44208 44210 44211 44212 44300 44320 44322 44604 44605 44615 44625 44626 44660 44661 44799 45110 45111 45112 45113 45114 45116 45119 45120 45121 45123 45126 45130 45135 45550 45562 45563 45800 45805 45820 45825 45999

Urinary System: 51597 51925

Female Genital System: 57307 58150 58152 58180 58200 58210 58240 58260 58262 58263 58285 58550 58552 58553 58554 58951 58953 59135 59136 59140 59525

Instructions:

This measure is reported using the appropriate quality G-code indicator whenever the listed CPT services are provided for a patient undergoing surgery that typically requires the administration of prophylactic antibiotics. It is anticipated that this measure should reflect the management of the surgical patient to reduce complications from infections. Thus, it is anticipated that it may be appropriate for both the clinician performing the surgery and the clinician providing anesthesia services may submit this measure for a patient.

Among others reacting to the new PVRP, please see a letter from the American Medical Association (AMA) to CMS. Download a copy of the letter.