Since CMS implemented the physician quality reporting system (PQRS) under the Tax Relief and Health Care Act of 2006 (TRHCA), there have been several changes in participation sanctions, reporting mechanisms and eligibility for incentives and bonuses. During the first two years, the program was technically a temporary, renewable initiative that sought to improve the quality of both delivery and coordination of care. The initiative became permanent when the Medicare Improvement for Patients and Providers Act (MIPPA, 2008) was enacted.
The Centers for Medicare and Medicaid Services (CMS) believes the sanction-based initiative will empower consumers and providers to make better informed decisions through better information and incorporate cost-control measures that support high-quality medical care, rather than high-patient volumes.
While there has been some, although limited, flexibility in the past, the CMS PQRS Implementation guide released in January 2015 clearly demonstrates that negative sanctions will be imposed on “all eligible providers who do not meet the criteria for satisfactory reporting or participating for 2015 PQRS,” without exception. Penalties will kick in for performance year 2015 (reportable in 2017) at 1.5 percent and increase to 2 percent for performance years 2016 and 2017 (reportable in 2018 and 2019 respectively).
The role of electronic health records (EHR) is expanding. Providers participating in multiple programs benefit by using the eCQM specifications for data transmission that are standardized for PQRS portal reporting and Medicare EHR Incentive Programs.
The following updates will help private and group practice providers ensure their practice is prepared to meet minimum reporting and technology standards, and that they avoid negative sanctions going forward.
EHR-Based Reporting and Clinical Quality Measures (CQM)
Updated physician quality report system requirements stipulate that eligible providers and group practices may satisfy the CQM for Medicare EHR incentives by reporting electronically via an approved EHR. Providers must supply CMS with an EHR Certification Number. Both direct-submission and vendor-supported transmissions enable providers to avoid payment reductions.
The requirement to use the most recent version of Certified EHR Technology (CEHRT) to report eCQMs no longer applies; however, eligible providers must use current, or the most recent version of electronically specified clinical quality measures (eCQMs), if reporting electronically.
Direct-Reporting and Vendor-Supported Reporting
Before self-submitting data to CMS from a practice EHR, providers must register for an IACS account and request a submitter role be added to the account profile. Direct submissions from an EHR system maintained by medical providers or practice groups must be capable of submitting data using either QDM-based QEDA Category I or III formatting. If reporting data via vendor services, the vendor system must be capable of transmitting data in both formats.
EHR Measure Specifications
EP must report nine measures, while hospitals must report 16. The 2014 CQM Reporting Guide for Eligible Professionals provides in-depth details about the reporting process.
Updated 2014 National Quality Strategy (NSQ) domain rules require that at least three of the following domains are represented:
- Patient and Family Engagement
- Patient Safety
- Care Coordination
- Population/Public Health
- Efficient Use of Health Care Resources
- Clinical Process/Effectiveness
The Expanding Role of Electronic Medical Records and EHR Software
The laudable CMS goal of improving patient experiences and outcomes via quality reporting mechanism may strain physician resources, especially if the independent provider is participating in multiple programs. Utilizing EHR technology to aggregate and parse data as part of the process improves accuracy and compliance.
There are multiple reporting mechanisms that include claim-based report generation, qualified registries, Group Practice Reporting Options (GPRO), and CMS-Certified Vendor protocol. Approved EHR software and certified systems fully aligned with CMS standards empower physicians to transmit data efficiently and accurately.