January 22, 2015
ASA Publishes PQRS FAQs; CMS Issues Guidance on the MAV Process
The American Society of Anesthesiologists® (ASA) recently published several Frequently Asked Questions (FAQs) regarding participation in the Physician Quality Reporting System (PQRS). PQRS is a voluntary reporting program that uses a combination of incentive payments (for reporting years 2007-2014) and payment adjustments or penalties (beginning in reporting year 2013) to promote reporting of quality information by eligible professionals (EPs). Under PQRS, covered professional services are those paid under or based on the Medicare Physician Fee Schedule (PFS).
For the 2015 reporting period, non-participation or failure to satisfactory report or satisfactorily participate in PQRS will subject EPs to a payment adjustment (penalty) of 2% on their covered professional services (applied in calendar year 2017). PQRS will also affect your Value-Based Payment Modifier (VM). For the VM, practices of two to nine EPs and solo practitioners who opt not to report PQRS or fail to satisfactorily report or satisfactorily participate risk a -2% modifier. Groups of 10 EPs who likewise fail to meet PQRS reporting criteria risk a -4% modifier.
Anesthesiologists may submit PQRS data to the Centers for Medicare & Medicaid Services (CMS) using a variety of reporting mechanisms including the Anesthesia Quality Institute’s National Anesthesia Clinical Outcomes Registry (NACOR) Qualified Clinical Data Registry (QCDR), claims, “traditional” qualified registry, electronic health records (EHR) or the Group Practice Reporting Option (GPRO). Regardless of reporting mechanism, EPs are generally required to report nine (9) measures across three (3) National Quality Strategy domains. However, each reporting mechanism includes different criteria for satisfactorily reporting or satisfactorily participating. The EP may choose which measures to report so long as the EP meets the criteria for reporting. The FAQs provide additional information and links to each of these reporting options.
For members reporting measures via the claims-based or “traditional” qualified registry, CMS recently released additional guidance on cross-cutting measures and the Measure-Applicability Validation (MAV) process for 2015. Reporting less than nine (9) measures across fewer than three (3) NQS domains or not reporting one cross-cutting measure via the claims or “traditional” qualified registry reporting mechanism triggers the MAV process. The MAV process is used to determine whether the EP should have submitted data on additional measures.
Cross-cutting measures and the MAV process are not applicable to those EPs participating in PQRS via the Qualified Clinical Data Registry (QCDR) reporting mechanism.
EPs and practices are encouraged to familiarize themselves with the ASA FAQs on PQRS 2015 as well as guidance documents released by CMS. For EPs using the claims-based or “traditional” qualified registry reporting mechanisms, where anesthesiologists have traditionally had limited measures to report, ASA also encourages EPs to contact the CMS QualityNet Help Desk at (866) 288-8912 or via e-mail at email@example.com to ensure they are reporting applicable measures.
For additional information, please contact the ASA Department of Quality and Regulatory Affairs (QRA) at (202) 289-2222 or via e-mail firstname.lastname@example.org.
Did you receive a letter from CMS on your non-participation in PQRS for 2013? Click on this Washington Alert for additional details and what that may mean to your practice in 2015.