Avoid Unexpected Penalties: Learn More about PQRS and Other Quality Reporting Diane M. Pedulla, J.D. American Psychological Association Colleen O Donnell, MSW, PMP, CHTS-IM National Council for Behavioral Health
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Physician Quality Reporting System Bonus of 0.5% on all Medicare charges for 2014 PQRS shifts from bonuses to penalties in 2015 Penalties: 1.5% in 2015; 2.0% in 2016 & 2017 Applies to all Medicare charges
2015 Requirements Must report on 9 measures across 3 domains for 50% of your eligible Medicare Part B FFS patients OR Must report on 20 patients for 1 measures group 11 of the 20 must be Medicare FFS patients Example of a measures group: dementia
Report on 3 of the 6 quality domains: Patient and Family Engagement Patient Safety Care Coordination Population/Public Health Efficient Use of Healthcare Resources Clinical Process/Effectiveness
Changes in 2015 Providers with at least one face-to-face patient encounter must include 1 cross-cutting measure Cross-cutting measures reflect patients functional status Examples: tobacco use assessment, depression screening, body mass index screening
PQRS reporting options Claims-based quality data listed on 1500 form. Cannot be added after claim is submitted. Registry Data submitted to a qualified vendor Higher success rate and customer support Requires an annual fee Electronic Health Records requires certified technology
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Individual measures Preventive care and screening: Body mass index screening and follow-up (#128) Documentation and verification of current medications in the medical record (#130) Pain assessment prior to initiation of patient therapy and follow-up (#131) Screening for clinical depression and follow-up plan (#134)
Individual measures Elder maltreatment screen and follow-up plan (#181) Preventive care and screening: Tobacco use assessment and tobacco cessation intervention (#226) Adult major depressive disorder (MDD): Coordination of care of patients with specific comorbid conditions (#325)
Quality Domains Patient Safety: #130 Documentation of medication #181 Elder maltreatment Effective Clinical Care: #107 Adult MDD suicide risk assessment (EHRs only) #325 Adult MDD coordination of care of patients with comorbid conditions (registry reporting only)
Quality Domains Community / Population Health: #126 Preventive screening BMI #131 Pain assessment and follow-up #134 Preventive Care: Depression screening #173 Preventive Care: Unhealthy alcohol use
New measures for 2015 Anti-psychotic medications for individuals with schizophrenia (#383) Follow-up after hospitalization for mental illness (#391) - applies to children age 6 & older as well as adults Both can be reported through a registry or EHR but not claims-based reporting.
Measures eliminated in 2015 Major depressive disorder: diagnostic evaluation (#106) Substance use disorders counseling (#247) Substance use disorders screening for depression (#248)
Meaningful Use Eligible Professional (EP) Clinical Quality Measures and PQRS Brief review of 2011-2013 CQM reporting structure Main focus is on CQM (2014 criteria) reporting for 2015 Requirements and avenues for reporting Aligning 2015 NQF and PQRS reporting Conditions for making one report to satisfy both
Medicare EP Incentive Program (2011-2013 Certified EHR) CQM Reporting Structure Meaningful Use CQMs Core Objective Three Core Measures (adults) OR Three Alternate Core (children / elderly) AND Three Menu Measures (selected from list of 38) No threshold, but required to report Medicare EP disincentives begin at -1% for 2015, increase until -5%
Medicare EHR EP Incentive Program (2014 Certified EHR) 2015 CQM Reporting Structure List of 64 CQMs Includes 9 recommended for adults, and 9 recommended for pediatric Cross-cutting measures list 2015 PQRS CMS GPRO cross-walked to 2015 NQF
Alignment of PQRS and CQMs EHR-Based PQRS Reporting Measure Set Same as EP Clinical Quality Measure Reporting Menu (for Stage 2 Meaningful Use) EPs must use EHRs with 2014 CEHRT and also PQR-approved to receive incentives PQRS-Medicare EHR Incentive Pilot Participation Guide
2015 Program Year Meaningful Use CQM Reporting Options Meaningful Use Incentives Only Option 1: EHR Registration and Attestation System Option 2: ereport CQMs through PQRS Portal To align with other quality programs Option 3: Individual EP CQMs through PQRS Portal Option 4: Group CQMs through PQRS Portal Option 5: Group CQMs through Pioneer ACO or Comprehensive Primary Care Initiative participation
Value-Based Payment Modifier Automatic 1% value modifier adjustment to payment under the Medicare Physician Fee Schedule, based on cost and quality data already reported (i.e., PQRS, Quality and Resource Use Reports) Registration for PQRS Group Practice Reporting Option closed 9/2014 Participation now mandatory, and applied to: 2015 payments (based on 2013 data) for group practices of 100 or more Eligible Professionals (EPs) who submit Medicare claims under a single Tax Identification Number (TIN) AND volunteered for reporting. 2016 payments (based on 2014 data) for group practices of 10 or more EPs who participate in fee-for-service Medicare under a single TIN. 2017 payments (based on 2015 data) to all physicians who participate in fee-for-service Medicare. Look for benchmark publication 9/2014 and for more details: http://www.cms.gov/medicare/medicare-fee-for-service- Payment/PhysicianFeedbackProgram/index.html
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Changes in reporting options Registry reporting only: Antidepressant medication during acute phase for patients w/ MDD (#9) Preventive care & screening: Unhealthy alcohol use screening (#173) Electronic health records reporting only: Adult MDD suicide risk assessment (#107)
The need for a registry CMS is phasing out claims-based reporting. All measures groups and some individual measures are ineligible for claims-based reporting. Example: psychologists can no longer report the measure group on dementia through claims.
Advantages of registries Quality data submitted separately from claims. Data can be entered after the reporting year ends Registry updates all measure changes annually. Registries provide EPs with feedback reports. Success rates: 95+% for registries vs. 55% for claims-based reporting
The APAPO registry APAPO is offering a mental and behavioral healthfocused PQRS registry Registry is being operated by Healthmonix, a qualified vendor since 2009 The fee for each reporting period is $199/provider Example: 2014 is one reporting period Discounts for groups of 5-29 ($179) and 30+ ($159)
The APAPO Registry To report data for services furnished in 2014: Must sign up with the registry by 1/31/15 Sign up online at https://apapo.pqrspro.com Registry accepting data up to mid-february
More Questions? American Psychological Association APAPO Government Relations Office Telephone: 202-336-5889 Email: pracgovt@apa.org View PQRS articles at www.apapracticecentral.org National Council for Behavioral Health Colleen O Donnell, MSW, PMP, CHTS-IM ColleenO@thenationalcouncil.org