Administrative Claims is a deceptively attractive option for PQRS in 2013. The danger is that most organizations choosing the Administrative Claims option are doing nothing in 2013 to build or improve their PQRS submission processes. Taking 2013 off may prove to be costly. With rising penalties and increasing submission requirements, organizations who are not using 2013 to build and improve PQRS data and data flow are putting themselves at increased risk of failure in future years—future years that have an ever-increasing cost of failure.
Until now, PQRS submission has been mostly a technical exercise. Medicare has essentially rewarded providers for participating, requiring few measures and setting a low bar for performance. 2013 marks a turning point. If the 2014 rules are adopted as proposed and trends continue as predicted:
- 9 measures, rather than 3 will be required for each submission
- Any remaining incentive disappears after 2014
- Administrative claims will not be an option for any year beyond 2013
- It will be progressively harder to avoid the adjustment
- Value-Based Modifier, Meaningful Use, Accountable Care, and other Medicare reporting programs will steadily converge on the PQRS reporting model
- Penalties relating to each program are increasing and additive.
- By 2017, 7% of Medicare allowable charges may be forfeited without a PQRS submission
Given that PQRS submissions are getting more complex, it is increasingly likely that your first PQRS submission will fail. The best to expect from a first submission may be to identify failure points that can be fixed to be successful the next year. And considering that the value-based modifier is effectively putting us in competition with one another on measured cost and quality, even a history of successful PQRS submissions may not be predictive of future success without continued attention to detail.
Three Good Reasons to Make A Group Practice Reporting Option (GPRO) Registry Submission for 2013:
ONE: It is better protection than Administrative Claims against the 2015 payment adjustment.
Administrative Claims has never been used before, has never been tested, and will likely never be used again. Once you commit to Administrative Claims, the outcome is out of your hands and will not be revealed until mid-2014 when it is too late to engineer a different solution. Medicare DOES NOT GUARANTEE that Administrative Claims will protect you from the 2015 adjustment.
In contrast, though new to the GPRO process, Registry submissions are tried and true. In our hands, registry has a 99.9% success rate. We know when we submit that it will be effective. In 2013, it remains absurdly easy to avoid the 2015 adjustment with a registry submission. Submission of just one measure, applicable to one patient, for one provider, with a zero performance rate is enough to protect the whole group from the 2015 payment adjustment.
In 2014, it will take the same effort to avoid the 2016 adjustment as it will take to earn the 2014 incentive.
TWO: There is still money to be made.
In 2013, at 0.5%, the PQRS incentive is at an all-time low . After 2014, the incentive will be gone. In our experience, the incentive in nearly all cases, though small, is still more than enough to pay for submission. Medicare in 2013 and 2014 is still helping you pay to build and test your PQRS submission processes.
THREE: Experience. Habit.
For most of you, 2013 is the only year we will recommend and make a GPRO Registry submission. In 2014, we expect Medicare to introduce EMR-based submission methods for GPRO and to pressure EHR-enabled practices to use those methods. There are major technical and reliability differences between EHR-based and Registry submissions.
But the lessons learned in a 2013 Registry submission will still give you a head-start on your 2014 EHR-based submission.
Make a habit of reporting now–you’ll need it in the future as the stakes get higher.
Read more about the future of PQRS.
Want a personal consultation about your particular reporting challenges? Contact Mingle Health for a personal consultation.
Dr. Dan Mingle shares key changes and strategies for success in 2020 for MIPS.