PQRS 2017 Update - American Society of Anesthesiologists (ASA)

What is the Physician Quality Reporting System (PQRS)? 
PQRS was a quality reporting program that used negative payment adjustments to promote reporting of quality information by individual EPs and group practices. 2016 was the last program year for PQRS. In 2017, PQRS transitioned to the Merit-based Incentive Payment System (MIPS) under the Quality Payment Program. The final data submission timeframe for reporting 2016 PQRS quality data to avoid the 2018 downward payment adjustment was January through March 2017. The first MIPS performance period is the 2017 calendar year.

Why is PQRS important?
Non-participation or failure to satisfactorily report or satisfactorily participate in the 2016 PQRS reporting period will subject you to a 2 percent payment adjustment on your covered professional services in 2018. Non-PQRS reporters will also experience an additional penalty under the Value-Based Payment Modifier (VM).

For PQRS, EPs were required to report nine (9) measures across three (3) National Quality Strategy (NQS) domains. Providers and practices participating in the claims-based or qualified registry reporting mechanisms who did report 9 measures across 3 NQS domains must have reported on all applicable measures and successfully passed the Measure-Applicability Validation (MAV) process in order to successfully participate in PQRS and avoid a downward payment adjustment. For payment adjustment considerations, the MAV process determines whether an EP, who submitted data on fewer than 9 PQRS measures across 3 NQS domains, should have submitted additional measures to PQRS. Eligible professionals who fail MAV are subject to the 2018 payment adjustment. Information on how the 2016 PQRS MAV is applied is found on the CMS Analysis and Payment webpage.

2018 Physician Fee Schedule Update

For the 2018 payment year, CMS reduced the criteria for satisfactory reporting for the Physician Quality Reporting System (PQRS) for CY 2016 reporting period. The requirement was lowered from 9 measures across 3 NQS domains, where applicable, to only 6 measures with no domain or cross-cutting measure requirement. This is significant for many practices who have previously struggled to reach the higher threshold.

In addition, CMS eased downward adjustments in the value-based payment modifier (VM). Individuals and practices that satisfactorily participated in PQRS will be exempt from any negative VM that could have occurred via quality-tiering. CMS has reduced the automatic downward payment adjustment for those individuals and practices not meeting minimum PQRS criteria from negative four percent to negative two percent (-2.0 percent) for groups of ten or more clinicians; and from negative two percent to negative one percent (-1.0 percent) for physician and non-physician solo practitioners and groups of two to nine clinicians. Positive payments adjustments under the VM are available for those practices that demonstrated lower costs and higher quality care.

Please visit the CMS webpages listed below for additional resources on PQRS.

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For information on 2018 payments based upon 2016 PQRS participation, please contact the ASA Department of Quality and Regulatory Affairs at qra@asahq.org

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