2015 Updates to the Physician Quality Reporting System (PQRS) & the Value-based Payment Modifier
April 7, 2015 12:00 Noon EDT Phone: 1-877-267-1577 Passcode: 994 365 238
Presented by the Philadelphia Regional Office of CMS
2015 Updates to the Physician Quality Reporting System (PQRS) & - - PowerPoint PPT Presentation
2015 Updates to the Physician Quality Reporting System (PQRS) & the Value-based Payment Modifier April 7, 2015 12:00 Noon EDT Phone: 1-877-267-1577 Passcode: 994 365 238 Presented by the Philadelphia Regional Office of CMS 2 Topics
April 7, 2015 12:00 Noon EDT Phone: 1-877-267-1577 Passcode: 994 365 238
Presented by the Philadelphia Regional Office of CMS
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PQRS Value Modifier EHR Incentive Program
Total Medicare Payment Adjustment s at Risk for Non- Participatio n in PQRS and Meaningful Use in 2017
Pay Adj (2017)
2-9 EPs & solo 10+ EPs
Medicare Inc. (2015) Medicaid Inc. (2015)
Medicare Pay Adj (2017)
PQRS- Reporting (2017) Non-PQRS Reporting (2017) PQRS- Reporting (Up or Neutral Adj) (2017) PQRS- Reporting (Down Adj) (2017) Non- PQRS Reporting (2017)
MD & DO
MPFS
+2.0 (x), +1.0(x), or neutral
MPFS
+4.0 (x), +2.0(x),
MPFS
MPFS
$4,000- $12,000 (based
EP 1st demo MU)
$8,500 or $21,250 (based on when EP did A/I/U) $8,500 or $21,250 (based on when EP did
A/I/U)
MPFS
Physicians in groups
& Solo physicians : -7.0% Physicians in groups
10+ EPs:
DDM Oral Sur Pod.
N/A
Opt. Chiro.
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PQRS Value Modifier EHR Incentive Program
Total Medicare Payment Adjustments at Risk for Non-Participation in PQRS and Meaningful Use in 2017
Pay Adj. (2017) Groups of 2+ EPs Medicare Inc.
Medicaid
Medicare Pay
Practitioners
Physician Assistant
MPFS
EPs included in the definition of “group” to determine group size for application
modifier in 2017 (2
2017, VM only applies to payments made to physicians under the MPFS; beginning in 2018, VM will also apply to non-physician EPs N/A $8,500 or $21,250 (based on when EP did A/I/U) N/A
Nurse Practitioner Clinical Nurse Specialist N/A Certified Registered Nurse Anesthetist Certified Nurse Midwife $8,500 or $21,250 (based on when EP did A/I/U) Clinical Social Worker N/A Clinical Psychologist Registered Dietician Nutrition Professional Audiologits
Therapists
Physical Therapist
MPFS
See above N/A N/A N/A
Occupational Therapist Qualified Speech-Language Therapist
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1. Patient Safety 2. Person and Caregiver-Centered Experience and Outcomes 3. Communication and Care Coordination 4. Effective Clinical Care 5. Community/Population Health 6. Efficiency and Cost Reduction
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Claims
If EP sees at least 1 Medicare patient in a face-to-face encounter, must report on at least 1 cross-cutting measure AND report each measure for at least 50 percent of the Medicare Part B FFS patients seen during the reporting period to which the measure applies. Measures with a 0 percent performance rate would not be counted. (Subject to MAV)
Individual Reporting Criteria for the 2017 PQRS Payment Adjustment
Individual Measures What Measure Type? Can you report at least 9 measures covering at least 3 domains? Yes No
Report at least 9 measures covering at least 3 NQS domains Report 1—8 measures covering 1—3 NQS domains
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NQS Domain Measure Title Claims CSV Registry EHR
GRPO Web Interface
Measures Group Other Quality Programs Community/Population Health Tobacco Use and Help with Quitting Among Adolescents X X Effective Clinical Care Hepatitis C: One-Time Screening for Hepatitis C Virus (HCV) for Patients at Risk X Communication and Care Coordination Medication Reconciliation X X Communication and Care Coordination Care Plan X X X Community/Population Health Preventive Care and Screening: Influenza Immunization X X X X X ACO MU2 Community/Population Health Pneumonia Vaccination Status for Older Adults X X X X X ACO MU2 Effective Clinical Care Diabetes: Hemoglobin A1c Poor Control X X X X X ACO MU2
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NQS Domain Measure Title Claims CSV Registry EHR
GRPO Web Interface
Measures Group Other Quality Programs Community/Population Health Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan X X X X X ACO MU2 Patient Safety Documentation of Current Medications in the Medical Record X X X X X ACO MU2 Communication and Care Coordination Pain Assessment and Follow-Up X X X Community/Population Health Preventive Care and Screening: Screening for Clinical Depression and Follow-Up Plan X X X X X ACO MU2 Communication and Care Coordination Functional Outcome Assessment X X Community/Population Health Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention X X X X X ACO MU2 Million Hearts
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NQS Domain Measure Title Claims CSV Registry EHR
GRPO Web Interface
Measures Group Other Quality Programs Effective Clinical Care Controlling High Blood Pressure X X X X ACO MU2 Million Hearts Community/Population Health Childhood Immunization Status X MU2 Community/Population Health Preventive Care and Screening: Screening for High Blood Pressure and Follow-Up Documented X X X X X ACO MU2 Million Hearts Patient Safety Falls: Screening for Fall Risk X X ACO MU2 Person and Caregiver Experience and Outcomes CAHPS for PQRS Clinician/Group Survey X ACO Communication and Care Coordination Closing the Loop: Receipt of Specialist Report X MU2
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Qualified Registry
Individual Reporting Criteria for the 2017 PQRS Payment Adjustment
Individual Measures
What Measure Type? Measures Groups
Report at least 1 measures group, AND report each measures group for at least 20 patients, a majority (11 patients, if 20 submitted) of which much be Medicare Part B FFS patients. Measures groups containing a measure with a 0 percent performance rate will not be counted. If EP sees at least 1 Medicare patient in a face-to-face encounter, must report on at least 1 cross-cutting measure AND report each measure for at least 50 percent of the Medicare Part B FFS patients seen during the reporting period to which the measure applies. Measures with a 0 percent performance rate would not be counted. Can you report at least 9 measures covering 3 domains?
Yes No
Report at least 9 measures covering at least 3 NQS domains Report 1—8 measures covering 1—3 NQS domains (Subject to MAV)
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measures that have a particular clinical condition or focus in common
patients in the sample seen by the EP during the reporting period
Diabetes Chronic Kidney Disease Preventive Care Coronary Artery Bypass Graft Rheumatoid Arthritis Acute Otitis Externa (AOE) Cataracts Hepatitis C Heart Failure Coronary Artery Disease Optimizing Patient Exposure to Ionizing Radiation HIV/AIDS Asthma Chronic Obstructive Pulmonary Disease Inflammatory Bowel Disease Sleep Apnea Dementia Parkinson’s Disease Sinusitis Oncology Total Knee Replacement General Surgery
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Direct EHR product that is CEHRT –OR- EHR data Submission vendor that is CEHRT
Report 9 measures covering at least 3 of the NQS domains. If an EP's CEHRT or EHR data submission vendor does not contain patient data for at least 9 measures covering at least 3 domains, then the EP must report the measures for which there is Medicare patient data. An EP must report on at least 1 measure for which there is Medicare patient data.
Individual Measures What Measure Type? 16
are available report 1 outcome measure and 1 additional of the following:
– Patient Safety – Resource Use – Patient experience of care – Efficiency/appropriate use
publicly report the quality measure data collected and provide a link to those data to CMS to include on Physician Compare OR the QCDR must provide data to Physician Compare to consider for public reporting
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Qualified Clinical Data Registry
Report at least 9 measures covering at least 3 NQS domains AND report each measure for at least 50 percent of the EP’s applicable patients seen during the reporting period to which the measure applies. Of the measures reported via a qualified clinical data registry, the EP must report on at least 2 outcome measures, OR if 2 outcome measures are not available, report on at least 1 outcome measure and at least 1 of the following: resource use, patient experience of care, efficiency/appropriate use, or patient safety
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Individual PQRS measures and/or non-PQRS measures reportable via a QCDR
What Measure Type?
– GPRO Web Interface available for groups of 25+ EPs
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Qualified Registry
2-99 EPs Group Practice Size?
If group practice sees at least 1 Medicare patient in a face-to-face encounter, must report on at least 1 cross-cutting measure AND report each measure for at least 50 percent of the Medicare Part B FFS patients seen during the reporting period to which the measure applies. Measures with a 0 percent performance rate would not be counted.
Can the group report at least 9 measures covering at least 3 domains? Yes No
Report at least 9 measures covering at least 3 NQS domains Report 1—8 measures covering 1—3 NQS domains
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Direct EHR product that is CEHRT
EHR data submission vendor that is CEHRT
Report 9 measures covering at least 3 of the NQS domains. If a group practice's CEHRT does not contain patient data for at least 9 measures covering at least 3 domains, then the group practice must report the measures for which there is Medicare patient data. A group practice must report on at least 1 measure for which there is Medicare patient data.
2-99 EPs Group Practice Size? 21
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GPRO Web Interface
Group Practice Size? 25+ EPs
Report on all measures included in the web interface; AND Populate data fields for the first 248 consecutively ranked and assigned beneficiaries in the order in which they appear in the group’s sample for each module or preventive care measure. If the pool of eligible assigned beneficiaries is less than 248, then report
*A PQRS group practice is required to report on at least one measure for which there is Medicare patient data. Groups of 100+ EPs: In addition, the group practice must report all CG CAHPS survey measures via certified survey vendor.
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GPRO Measure Number Measure Title Care Coordination/Patient Safety (CARE) Measures (2 Measures- Individually Sampled) CARE-2 Falls: Screening for Future Fall Risk CARE-3 Documentation of Current Medications in the Medical Record GPRO Measure Number Measure Title Coronary Artery Disease (CAD) Disease Module (1 Measure) CAD-7 Coronary Artery Disease (CAD): Angiotensin-Converting Enzyme (ACE) Inhibitor or Angiotensin Receptor Blocker (ARB) Therapy - Diabetes or Left Ventricular Systolic Dysfunction (LVEF < 40%)
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GPRO Measure Number Measure Title Diabetes Composite (2 Components of 1 Composite Measure) (CMS-related Composite) Composite: (All or Nothing Scoring) DM-2 Composite (All or Nothing Scoring): Diabetes: Hemoglobin A1c Poor Control DM-7 Composite (All or Nothing Scoring): Diabetes: Eye Exam
GPRO Measure Number Measure Title
Heart Failure (HF) Disease Module (1 Measure) HF-6 Heart Failure (HF): Beta-Blocker Therapy for Left Ventricular Systolic Dysfunction (LVSD)
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GPRO Measure Number Measure Title
Hypertension (HTN) Disease Module (1 Measure) HTN-2 Controlling High Blood Pressure
GPRO Measure Number Measure Title
Ischemic Vascular Disease (IVD) Disease Module (2 Measures) IVD-2 Ischemic Vascular Disease (IVD): Use of Aspirin or Another Antithrombotic
GPRO Measure Number Measure Title
Mental Health (MH) Disease Module (1 Measure) MH-1 Depression Remission at Twelve Months
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GPRO Measure Number Measure Title Preventive (PREV) Care Measures (8 Measures – Individually Sampled) PREV-5 Breast Cancer Screening PREV-6 Colorectal Cancer Screening PREV-7 Preventive Care and Screening: Influenza Immunization PREV-8 Pneumonia Vaccination Status for Older Adults PREV-9 Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan PREV-10 Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention PREV-11 Preventive Care and Screening: Screening for High Blood Pressure and Follow-Up Documented PREV-12 Preventive Care and Screening: Screening for Clinical Depression and Follow-Up Plan
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Report all CAHPS for PQRS survey measures via a CMS-certified survey vendor PLUS:
Qualified Registry
Report at least 6 additional measures outside of CAHPS for PQRS, covering at least 2 NQS domains; if less than 6 apply to group, report up to 5 measures. If EP in group sees at least 1 Medicare patient in face-to- face encounter, must report at least 1 cross-cutting measure.
GPRO Web Interface (25+ EPs only)
Report on all measures included on web interface; AND populate data fields for first 248 consecutively ranked and assigned beneficiaries in the order in which they appear in the group’s sample for each module or preventive care measure. If the pool of eligible assigned beneficiaries is less than 248, then report on 100 percent of assigned beneficiaries
Direct EHR product that is CEHRT -OR- EHR data submission vendor that is CEHRT
Report at least 6 additional measures outside of CAHPS for PQRS, covering at least 2 NQS domains; if less than 6 apply to group, report up to 5 measures. Group practice required to report
there is Medicare patient data.
Groups of 2-99 EPs: Optional Methods Below Groups of 100+ EPs: MANDATORY….MUST CHOOSE ONE OF THESE OPTIONS 29
VM in CY 2017
practitioners receive only the upward or neutral VM adjustment under quality-tiering
Shared Savings Program, Pioneer ACO Model, CPC Initiative, or
during the CY 2015 performance period
EPs in groups with 2+ EPs and to non-physician EPs who are solo practitioners
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Value Modifier Components 2015 Finalized Policies 2016 Finalized Policies 2017 Finalized Policies
Performance Year 2013 2014 2015 Group Size 100+ 10+ 2+ EPs and solo practitioners Available Quality Reporting Mechanisms GPRO-Web Interface, CMS Qualified Registries, Administrative Claims GPRO-Web Interface, CMS Qualified Registries, EHRs, and 50% of EPs reporting individually Same as 2016 Payment at Risk
practitioners)
Outcome Measures NOTE: The performance on the
reported through the PQRS reporting mechanisms will be used to calculate a quality composite score for the group for the VM. All Cause Readmission Composite of Acute Prevention Quality Indicators: (bacterial pneumonia, urinary tract infection, dehydration) Composite of Chronic Prevention Quality Indicators: (chronic
(COPD), heart failure, diabetes) Same as 2015 Same as 2015 Patient Experience Care Measures N/A PQRS CAHPS: option for groups of 25+ EPs CAHPS for PQRS: Optional for groups with 2-99 EPs; required for all groups with 100+ EPs Groups may elect to include their CAHPS results in the calculation of the 2017 VM
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Value Modifier Components 2015 Finalized Policies 2016 Finalized Policies 2017 Finalized Policies
Cost Measures Total per capita costs measure (annual payment standardized and risk-adjusted Part A and Part B costs) Total per capita costs for beneficiaries with four chronic conditions: COPD, Heart Failure, Coronary Artery Disease, Diabetes Same as 2015 and: Medicare Spending Per Beneficiary measure (includes Part A and B costs during the 3 days before and 30 days after an inpatient hospitalization) Same as 2016 Benchmarks Cost: - 100+EPs TINs are compared against groups of 100+ EPs
against 1+ EP TINs Quality: No differentiation by group size No differentiation by group size (“compared to everyone”) for both cost and quality measures No differentiation by group size (“compared to everyone”) for both cost and quality measures Quality Tiering Optional Mandatory Groups of 10-99 EPs receive only the upward (or neutral) adjustment, no downward
both the upward and downward adjustment apply (or neutral adjustment). Mandatory: Groups with 2-9 EPs and solo practitioners receive only the upward or neutral VM adjustment (no downward adjustment) Groups with 10+ EPs can receive upward, neutral, or downward VM adjustment Application of the VM to Participants of the Shared Savings Program, Pioneer ACO Model, and the CPC Initiative Not applicable Not applicable Applicable (See slides 38 & 39)
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Value Modifier Components 2015 Current Policy 2015 Finalized Policy 2016 & 2017 Finalized Policies
VM Informal Review Process: Timeline Not specified. After the dissemination of the annual Physician Feedback reports, a group of physicians may contact CMS to inquire about its report and the calculation
modifier. Deadline of February 28, 2015 for a group to request correction of a perceived error made by CMS in the 2015 VM payment adjustment. Establish a 60 day period that would start after the release of the QRURs for the applicable reporting period for a group or solo practitioner (as applicable) to request correction of a perceived error made by CMS in the determination of the group or solo practitioner’s VM for that payment adjustment period. VM Informal Review Process: If CMS made an error Not specified
quality” in the event we determine that we have made an error in the calculation of quality composite.
composite if CMS made an error in its calculation.
composite in the event we determine that we have made an error in the calculation of quality composite.
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meeting the satisfactorily reporting criteria to avoid the 2017 PQRS payment adjustment.
(‘x’ represents the upward VM payment adjustment factor).
harmless from any downward adjustments under quality-tiering in 2017.
Cost/Quality Low Quality Average Quality High Quality Low Cost +0.0% +1.0x* +2.0x* Average Cost +0.0% +0.0% +1.0x* High Cost +0.0% +0.0% +0.0%
* Eligible for an additional +1.0x if reporting PQRS quality measures and average beneficiary risk score in the top 25 percent of all beneficiary risk scores
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for not meeting the satisfactory reporting criteria to avoid the 2017 PQRS payment adjustment.
to +4.0x (‘x’ represents the upward VM payment adjustment factor), and the maximum downward adjustment is -4.0%.
* Eligible for an additional +1.0x if reporting PQRS quality measures and average beneficiary risk score in the top 25 percent of all beneficiary risk scores
Cost/Quality Low Quality Average Quality High Quality Low Cost +0.0% +2.0x* +4.0x* Average Cost
+0.0% +2.0x* High Cost
+0.0% 35
Do you plan to report for PQRS in 2015? Yes No Does the group plan to report PQRS as a group? No
Does group meet 50% threshold? All EPs (solo and in groups of 2+ EPs) will be subject to the 2017 PQRS payment adjustment of -2.0% All solo physicians and physicians in groups of 2-9 EPs will be subject to the 2017 VM downward adjustment
All physicians in groups
subject to the 2017 VM downward adjustment
Solo Yes
avoid 2017 PQRS payment adjustment
neutral VM adjustment in 2017
payment adjustment. For the 50% threshold option, at least 50% of the EPs must report to avoid the 2017 PQRS payment adjustment
Subject to upward or neutral VM adjustment
neutral or downward VM adjustment
No Yes Are you a solo EP or part of a group? Are you a physician?
2017 PQRS payment adjustment
apply to non- physician EPs in 2017
Group No Yes
How Does 2015 PQRS Participation Affect the VM in 2017?
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Claims Qualified Registry EHR/ DSV QCDR GPRO Web Interface CAHPS Survey PQRS Reporting VM: PQRS- Reporter VM: PQRS Non- Reporter
Solo physician
Avoid 2017 PQRS adj (-2.0%) Upward/Neutral adj (+1.0x, +2.0x, 0.0%)
Downward adj Solo Non- physician Practitioner
Avoid 2017 PQRS adj (-2.0%) Does not apply in 2017 Does not apply in 2017 Group 2-9 EPs
Optional Avoid 2017 PQRS adj (-2.0%) Upward/Neutral adj (+1.0x, +2.0x, 0.0%)
Downward adj Group 10-24 EPs
Optional Avoid 2017 PQRS adj (-2.0%) Upward/Neutral/ Downward adj (+4.0x, +2.0x, 0.0%, -2.0%, 4.0%)
Downward adj Group 25-99 EPs
Optional Avoid 2017 PQRS adj (-2.0%) Upward/Neutral/ Downward adj (+4.0x, +2.0x, 0.0%, -2.0%, 4.0%)
Downward adj Group 100+ EPs
Mandatory Avoid 2017 PQRS adj (-2.0%) Upward/Neutral/ Downward adj (+4.0x, +2.0x, 0.0%, -2.0%, 4.0%)
Downward adj
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summary surveys
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– 866-288-8912 (TTY 877-715-6222) – 7:00 a.m.–7:00 p.m. CST M-F or qnetsupport@hcqis.org – You will be asked to provide basic information such as name, practice, address, phone, and e- mail
– Questions on status of 2013 PQRS/eRx Incentive Program incentive payment (during distribution timeframe) – See Contact Center Directory at http://www.cms.gov/MLNProducts/Downloads/CallCenterTollNumDirectory.zip
– 888-734-6433 (TTY 888-734-6563)
– 888-734-6433 Option 2 or cmsaco@cms.hhs.gov
– 800-381-4724 or cpcisupport@telligen.org
– Monday – Friday: 8:00 am – 8:00 pm EST
– Phone: 888-734-6433, press option 3
– Email: PhysicianCompare@westat.com
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https://s3.amazonaws.com/public-inspection.federalregister.gov/2014-26183.pdf
http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms
http://cms.gov/Medicare/Medicare-Fee-for-Service-Payment/sharedsavingsprogram/Quality_Measures_Standards.html
http://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PhysicianFeedback Program/ValueBasedPaymentModifier.html
http://www.medicare.gov/physiciancompare/search.html
https://questions.cms.gov/
http://cms.gov/Outreach-and-Education/Outreach/FFSProvPartProg/Index.html
https://public-dc2.govdelivery.com/accounts/USCMS/subscriber/new?topic_id=USCMS_520
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Lolita Jacobe (415-744-3531) Lolita.jacobe@cms.hhs.gov Region X: AK, ID, OR, WA Lauri Tan (206-615-2324) Lauri.tan@cms.hhs.gov
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