Eye Surgeons Should Focus On These 2015 PQRS Challenges

Eye Surgeons Should Focus On These 2015 PQRS Challenges

What are some of the most pressing issues or challenges facing eye surgeons in the coming year?

Strategies developed by the Affordable Care Act continue to move through their stated trajectories. Over the last two years (2013 and 2014), medical providers have been coming into compliance with the Electronic Health Records standards, implementing “Meaningful Use” practices and collecting relevant health data across their patient bases. Continuing toward full implementation of the National Strategy for Quality Improvement in Health Care, the reporting and compliance requirements for 2015 are a little tighter and more rigorous than those in previous years.

Satisfactory Reporting is Key:

Not surprisingly, reporting continues to play an immense role in the plan. The Physician Quality Reporting System (PQRS) captures the metrics of quality care from eligible professionals (EP’s) and group practices. The PQRS shares that data with the US Centers for Medicare and Medicaid Services (CMS). With the aggregate data, the CMS can better evaluate the overall status of the health of the country’s population. The CMS also uses the data to review the quality of care provided and can compare that to the ‘best practice’ standards established by the ACA. In 2013 and 2014, ophthalmologists were rewarded with incentives for participating in the processes of data collection and reporting.

Satisfactory reporting will also be critical for the collection of optimal fee values after implementation of the CMS fee schedule changes that are expected in 2016. Released July 1, 2015, the proposed 2016 rule is one of many new rules designed to further align and optimize health care delivery and spending. For Ophthalmologists who use Ambulatory Surgical Centers, CMS is proposing a 2% cut in annual payments for entities that fail to meet the Ambulatory Surgical Center Quality Reporting (ASCQR) program reporting standards.

In the release, the CMS states it is also seeking comments regarding the possible addition of a new ophthalmic measure. Ophthalmologists interested in commenting on the percentage of “Unplanned Anterior Vitrectomies” in cataract surgery patients are encouraged to contact the CMS before August 31, 2015.

2015 – Introduction of Reductions in Medicare Fee Payments for Unsatisfactory Reporting:

For the first time, however, in 2015, the program will apply a negative payment adjustment, reducing the Medicare fees paid to physicians who did not satisfactorily report data or quality measures on the 2013 Medicare Part B Physician Fee Schedule (MPFS). To avoid a similar fee cut expected in 2017, EP’s and practices must satisfactorily report their data for 2015.

Satisfactory Reporting Accomplished Through One of Six Options:

In 2015, “satisfactory reporting” will require that physicians report nine clinical quality measures (CQM) across three quality domains. There are six Reporting Options available to ensure that every professional can report an accurate account of their specific practice:

1)     IRIS™ Registry EHR System Integration: Those American Academy of Ophthalmology (AAO) members with EHR can access the AAO registry tool to extract report data. There is flexibility regarding the data recovered (those without nine CQMs can report other Medicare Part B information instead), and it requires no additional manual data entry. The medical office must have 2014-certified EHR systems in place for the full year.

2)     Direct EHR Product: Use of this reporting tool requires an EHR system that connects directly to the CMS reporting program.

3)     Cataracts Measures Group: There are eight measures in the cataracts group that can be reported through the IRIS Registry. Satisfactory reports will include at least 20 patients, 11 of whom are Medicare Part B recipients, and the balance of whom have Medicare Part B or commercial insurance. There is no opportunity here for reporting on “meaningful use” measures.

4)     Individual Measure Reporting via IRIS Registry Web portal (no EHR): There are two options here:

  1. a) Individually report nine measures across three domains on at least 50% of qualifying patients. At least one “cross-cutting measure must be included.
  2. b) There are 19 specific ophthalmic measures that can reported through the IRIS Registry, and EHR is not necessary. Physicians can also report on ophthalmology measures being developed by IRIS Registry that are not available in the PQRS measure set.

5)     Claims-Based Reporting for Your Office: In 2015, only eight measures that apply to most ophthalmic practices can be reported via this method, which is one short of the required nine reported measures. Offices reporting with this method can submit data on another measure to access the “measure application validity” process.

6)     Group Reporting Option: Ophthalmologists who are part of a large multi-specialty group practice may choose to report every physician in the “group-reporting” option.

Consequences of 2015 Reporting:

Satisfactory reports: For physicians who satisfactorily report their 2015 data, the rewards are many: avoidance of the 2017 negative payment adjustment of -2%; satisfaction of the CQM component of the EHR Incentive program; the possibility of receiving an added payment adjustment if 50% or more of the EP’s in groups of 2-9 or 10+ physicians report under PQRS as individuals; and the opportunity to receive a positive payment adjustment if their beneficiary risk score is in the top 25% of national scores.

Unsatisfactory Reports:

There are penalties for not meeting the 2015 PQRS reporting standards: a -2% negative payment adjustment (assessed in 2017); disqualification from the CQM EHR Incentive program (for this term); in groups of 2-9 practitioners, a -2% payment reduction if less than 50% report satisfactorily and in groups of 10+ P’s, a -4% reduction of 4% if less than 50% report satisfactorily.

The ACA has introduced dramatic systems changes across the health care industry in the United States and is expected to create even higher burdens of reporting of processes and outcomes in the future. For every health practitioner, including Ophthalmologists, the changes are challenging and, in many cases, represent a complete overhaul of medical business practices to comply fully with the law. However, with careful attention to these complex administrative details, every medical practice can improve both their business practice and the health of their patients. Let us help your practice satisfy the 2015 PQRS reporting requirements.