February 20, 2013
The first step with all compliance is identifying a compliance requirement. For healthcare practitioners there are so many requirements its very difficult to keep up, which is why we try to stay on top of all we can to keep you in the loop. Today's email is to highlight some basics about CMS's Physician Quality Reporting System and the coming payment adjustment for "eligible professionals". Beginning in 2015, CMS is going to penalize practitioners for their failing to provide qualitative data to CMS as required by CMS's Physician Quality Reporting System. Info from CMS - CMS Physician Quality Reporting System Page. CMS Physician Quality Reporting System Overview - February 2013 Overview.
The way CMS introduces potential penalties for failing to report is interesting - here, it seems ALL practitioners are included in the penalty UNLESS you meet reporting criteria. So everyone is scheduled for reduction, unless you show you are reporting. And, if you work at multiple practices, not only do you have to show you are reporting for one practice, you are required to show you are reporting for EACH tax identification number under which you work during the PQRS program year to avoid a payment adjustment.
The reporting specifications required for compliance have not yet been promulgated, however, it appears that practices with EMR will likely not have an issue complying, so long as they are actually aware of the requirement and ensure information they have on hand they are required to share with CMS is being transmitted properly to ensure they are not at risk of incurring the penalty. I believe this to be the case because in the CMS materials discussing its Physician Quality Reporting System, CMS specifies one criteria for avoiding penalties is to "report at least one valid measure OR one valid measure group". What constitutes a "valid measure" is not clear, but will be defined in the coming months.
The payment adjustment (penalty) for failing to report will be 1.5% of your allowable Medicare Part B reimbursement for covered services, and in 2016 and after that percentage rises to 2.0%.
If you are a member of a group practice, your practice may elect to participate in CMS's group practice reporting option - where you self-nominate or register to participate in the Physician Quality Reporting System as a group and all providers under your Tax ID who bill Medicare Part B will be included for analysis purposes of the payment adjustment. Accountable Care Organizations will also be able to participate in the group practice reporting option, and as such language provided by CMS indicates participants thereof will be exempt from further action to avoid the penalty.
For assistance registering as a Group Practice, contact me directly at (516) 747-6700 x. 302 or Jennifer@Kirschenbaumesq.com.