What Are Your 2016 PQRS Registry Reporting Options?
No two medical practices are alike. They vary in structure, specialties and number of practitioners. But even with all of these differences, every practice must participate in PQRS or face at least a 2% penalty on future Medicare payments.
The penalties may be similar, but the path for filing can be different. Below are your three 2016 PQRS registry reporting options:
Measure Groups – Individual Submissions
Measure Groups are an individual submission, meaning each provider in a practice files separately, rather than all together. A Measure Group is a set of measures centered around a common theme or specialty, such as diabetes care, oncology or hepatitis C treatment.
The provider will need to report on 20 eligible patients that meet specific Measure Group criteria. Eleven of these patients must have Medicare Part B insurance.
Benefits
This is usually the best option for small practices, since this option only requires the provider to report on 20 patients. That makes for a manageable amount of data that can be entered into our online tools any time throughout the year, either all at once or in bits and pieces at a time. If this option is for you, your 2016 PQRS submission could be finished already.
Disadvantages
Not everyone will have a Measure Group as an option. There are only 25 different Measure Groups and some specialties, for example dermatologists and pathologists, might not have a Measure Group that fits their specialty.
Entering the performance data for 20 patients for a Measure Group submission is a manual process. While this is manageable for smaller practices, it can be burdensome for larger groups. Those practices should explore the GPRO or Individual Measure reporting options.
Individual Measures – Individual Submissions
Using this option, all reporting providers must select nine measures – including one cross-cutting measure – across three domains.
Providers are required to report on at least 50% of the eligible Medicare patients for each measure, instead of just 20 patients needed for a Measure Group.
For example: If you have 1,000 patients in your practice, 500 of them have Medicare Part B insurance and 100 of them are diabetic, for Measure #1, HbA1C, you must report on 50 of those diabetic patients.
Even better, these specialties should consider reporting as group with the Group Practice Reporting Option.
Benefits
The benefits of using individual measures are that they cover almost all specialties.
And, if you can’t find nine measures across three domains to report, Measure Applicability Validation (MAV) test was specifically designed for you! MAV allows you to report all clinically-related measures, or in some cases, a single cross-cutting measure to make a qualifying submission to help avoid a negative adjustment.
If you can get detailed reports from your EMR, Individual Measure reporting would be easier for you. Instead of reviewing each chart, you may be able to submit a report that captures date for all your patients.
Disadvantages
Because the Individual Measures method requires reporting on most patients, it can be a demanding process if you are a large practice on paper records or without good reporting from your EMR.
It also means that your PQRS submission can’t be completed until the end of the calendar year. However, a mid-year analysis of billing information and data can help you get a head start and find measures that work for you.
If you miss the deadline to report as a Group, under the Group Practice Reporting Option (GPRO), you will be required to submit through Individual Measures or Measure Groups.
Group Practice Reporting Option (GPRO) – Group Submission
For the purpose of GPRO, a practice is defined by the Tax Identification Number (TIN). The practice must have two or more providers to use the GPRO. For practices that can’t use the Measure Group option, GPRO is the best alternative.”
Instead of each provider submitting nine measures in three domains for patients they saw, the practice submits as a group on patients seen by the group, regardless of who saw the patient.
Benefits
Instead of finding nine measures to report for each provider, the practice chooses one set of measures and all providers succeed in PQRS based on one submission.
It works very well for both multi-specialty and single specialty practices. Practices can select to report on measures related to a single specialty, or multiple specialties. The practice reports on the patients that are eligible for the measures they have chosen. Providers pass PQRS by being part of the practice and do not necessarily need to see the patients that were reported on.
Disadvantages
In order to file under GPRO, providers and practices need to select this option by June 30, which has already passed for 2016. If you missed the deadline, all providers in your practice will have to report through the Individual Measure or Measure Group option.
Succeed with PQRS Registry Reporting
While these are your PQRS registry reporting options, they aren’t the only way to satisfy PQRS for 2016. In our experience, even though each practice is unique, there’s a way to gather the necessary information to create a successful submission for any practice.
Let us know what reporting option your practice is planning to use, or ask us what mechanism we suggest for you! We’ll guide you every step of the way.
Dr. Dan Mingle and members of the team share their insights on how to maximize your success and payments for MIPS and APMs.