This ASH webinar details the use of the new ASH PQRSPro Registry System, a tool developed to facilitate the aggregation and submission of quality measure data to the Centers for Medicare & Medicaid Services Physician Quality Reporting System (PQRS). In the 2013 PQRS reporting year, a 0.5 percent incentive is still available for those who successfully report on quality measures; additionally, non-participation in 2013 will result in -1.5 percent “payment adjustment” on all reimbursements in 2015.The ASH PQRSPro system will validate that your reporting is incentive eligible and that you avoid impending payment adjustments.
Download the slides from the ASH PQRSPro webinar
Questions and Responses
The following questions were posed during the live presentation of the webinar. We have provided detailed responses for your reference. More information can be found at www.hematology.org/PQRS.
QUESTION: The penalty is based on percentage of all FFS charges. I assume this includes our E/M charges, but does this also include chemo administration charges and chemo drug charges?
ANSWER: The final PFS rule for 2013 (Page 69365, middle column section e) says the adjustment applies to covered professional services under the physician fee schedule. Thus, it would apply to E/M and chemo administration fees but not to payments for drugs which are paid outside of the PFS.
QUESTION: If I have patients with MDS who were tested for iron stores before receiving erythropoietin, but I did not specifically code for the iron testing (that is I only coded for the visit and the diagnosis), can I still report this as a measure in a registry?
ANSWER: If you follow the intent of the measure and have evidence and documentation in the chart that the test was done for iron stores as stated below, then you can still report this measure through a PQRS registry . Measure 68 defines the numerator as “patients with documentation of iron stores within 60 days prior to initiating erythropoietin therapy.” The following definitions also apply:
- Documentation of Iron Stores in the chart Includes either: 1) bone marrow examination including iron stain OR 2) serum iron measurement including ferritin, serum iron and TIBC.
- Erythropoietin Therapy includes the following medications: epoetin and darbepoetin for the purpose of this measure.
QUESTION: Did I understand that in order to avoid the penalty, I only have to report on one measure for one patient? (The measure reporting requirement seems to imply either 20 patients or a % of the baseline.) Is that done best through a registry or through claims reporting?
ANSWER: Yes. To avoid the 1.5% payment adjustment in 2015, you can report on one measure for one patient in 2013. This demonstrates to CMS that you are aware of the PQRS program and have technically ‘participated’ by following the process of reporting. Reporting 20 patients (for a Measures Group) or 80% of applicable Medicare patient visits (for at least 3 Individual Measures) will both avoid the 1.5% penalty in 2015 and earn an incentive payment of 0.5% for 2013.
QUESTION: What is the minimum reporting for the 0.5% incentive? Did I understand correctly: 3 measures for 20 patients. Can we use different measures for each patient?
ANSWER: The minimum reporting for the 0.5% incentive is different for a Measures Group reporting than for Individual Measures reporting:
For a Measures Group, you must report all of the applicable measures in the Measures Group for each of 20 unique patient visits, a majority of which (at least 11) must be Medicare Part B FFS. Measures Groups consist of 3 to 10 measures. You must answer all of the measures questions for each patient and you cannot use different patients for different measures in the group. The ASH PQRSPro system is ‘smart’ and interactive, enabling and/or disabling measure-specific chart abstraction questions based on responses.
For Individual Measures reporting, 80% of all Medicare Part B FFS patients who meet the denominator of each measure chosen must be reported (you must report at least 3 measures). In this case, different patient visits that fall within the denominator of each measure chosen are recorded. Again, the ASH PQRSPro system is ‘smart’ and interactive, enabling and/or disabling measure-specific chart abstraction questions based on responses.
QUESTION: How will CMS detect "grossly inaccurate data"?
ANSWER: This statement is in consideration of the qualified PQRS Registry data submission. All Registries must submit a Validation Plan and a Validation Execution Report to CMS every year to measure the accuracy of previously submitted data. NetHealth has been a qualified CMS Registry since 2009 and has had no issues with CMS related to “grossly inaccurate data.”
QUESTION: Define group vs. individual measures
ANSWER: Measures Group reporting requires submission of all of the applicable measures in the chosen Measures Group for each of 20 unique patients, a majority of which (at least 11) must be Medicare Part B FFS. Measures Groups consist of 3 to 10 measures. You must answer all of the measures questions for each patient entered. CMS has created Measures Groups with related measures and, in most cases, has homogenized the denominator so that all measures can be answered for the same patients.
Individual Measures reporting, the provider chooses at least 3 individual measures and must report 80% of Medicare Part B FFS patient visits that meet the denominator of the measure. In this case, different patient visits that fall within each measure chosen are recorded.
Note that the denominator criterion often differs for measures in a Measures Group, as opposed to Individual Measures. NetHealth PQRSPro takes this into account when measures are selected and chart data is entered.
QUESTION: We might have less than 100% compliance with a certain measure and we submit that. Will all these results be published on the CMS website?
ANSWER: PQRS is currently a Pay-for-Reporting program and actual performance rates will not be reported on the CMS Physician Compare website. What will be reported is successfully reporting PQRS data in 2013.
A 0% performance rate on any one measure will not be counted as satisfactory reporting for the measure. The recommended clinical quality action must be performed on at least one patient for each individual measure or measure within the measures group reported by the eligible professional. If allowed within a measure definition, performance exclusions are not counted in the performance denominator. If the eligible professional submits all performance exclusions for a measure, the performance rate of 0/0 is not 0% and is considered satisfactory reporting.
Occasionally, a measure is presented as a ‘reverse measure’ – in which a lower performance rate is better and you cannot have 100% reporting. An example is A1c reporting for diabetes measure #1.
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