It seems like the end of the 2015 PQRS reporting period wasn’t that long ago, with registries concluding their submission process on March 31st. But we are now more than halfway through 2016 with the end of the service year in sight. CMS will begin accepting PQRS submissions after December 31st. With a PQRS registry’s help, practices can start the reporting process and finish their submission any time before the March 31st, 2017 deadline. If you use a Measure Group to report, you can finish now.
However, it is now more important than ever to start the reporting process sooner rather than later in 2016. Here are several benefits practices and providers can take advantage of by starting the reporting process right now.
1. Put Time On Your Side
Beginning the PQRS reporting process right now allows you to spread out the work of reporting on a year’s worth of data over many months, as opposed to just a couple of weeks. A proactive approach can keep staff members who are responsible for reporting from being overwhelmed by the sheer enormity of the task.
The number of patients required to be reported on for an Individual Measures submission can easily reach into the thousands. The level of effort required can catch practices off guard who simply weren’t ready for that kind of volume. Spreading out the work eliminates the stress that comes with facing a short deadline.
Starting the PQRS submission process early also gives you the chance to uncover errors soon enough to have time to fix them before the reporting deadline. PQRS reporting can be a confusing process and misunderstandings can develop for providers or staff when it comes to exactly what documentation is required for a patient to “meet” a measure.
Perhaps there’s confusion over exactly what a measure means when it refers to a standardized tool or a follow-up plan. Working on the submission early can root out these problems and allow you to change the way information is being documented so that the quality action is met for the rest of the year going forward.
2. Get a Head Start with Quality Tiering
Providers can face potential penalties even if they submit PQRS data effectively. Successful submissions are still subject to the Quality Tiering process, where practices are compared on cost and quality to other practices with successful PQRS submissions.
Medicare calculates cost from the charges submitted by providers for patients attributed to the practice. Quality has two components: CMS calculated measures and PQRS measures.
With your 2016 PQRS submission, we can look at your performance rates on measures and compare them with CMS benchmark data. If we see that a practice or an individual provider is scoring lower than benchmark on a measure, it could be necessary to make changes in order to boost performance or switch to reporting a different measure.
However, once 2016 ends, it will be too late to put any changes in place to improve performance on a measure. And depending on how close it is to the submission deadline, there may not be enough time to gather data on alternate measures to report.
3. Give Yourself Prep Time for MIPS
In January 2017, we won’t just be ushering in the new year, but also a new CMS program: the Merit-Based Incentive Payment System, otherwise known as MIPS. From the Proposed Rule we know that practices will be scored on four performance categories. While the Final Rule for MIPS has not yet been released, you can help yourself prepare for MIPS by working on your 2016 PQRS submission.
Under MIPS, the Quality Performance Category is also two parts: CMS-calculated measures and provider submitted measures. In the first year of the program, the two quality categories together are proposed to make up 50% of a provider’s composite MIPS score. The provider-submitted measures will look much like the current PQRS program, where providers report on measures for eligible patients. Under PQRS, the Individual Measures submission method requires reporting on at least half of all eligible patients, but MIPS is proposed to increase to 90% reporting requirement for all payers.
By starting your PQRS submission early you can review the tools and mechanisms your practice has in place for gathering quality performance data. While some practices can scramble at the end of the year to manually determine performance via chart abstraction for half of their eligible patients, that method will be that much harder under MIPS with an increased reporting requirement.
Some ideas practices can implement now include:
- Reporting performance on a monthly basis to keep the number of eligible patients manageable throughout the year
- Assigning duties to personnel to include correct CPT II codes to indicate performance in billing claims
- Reviewing workflows for how to capture and report the data from your EMR
There’s a lot more that goes into MIPS than just quality reporting, and every practice will need to gear up for those new elements in the relatively short time between the Final Rule coming out in November 2016 and the start of the program in January 2017. By finishing your 2016 PQRS submission early, you can use the time normally spent starting the reporting process to focus on preparing for MIPS and getting your practice ready, instead of playing catch-up.
4. Save Your Place with a PQRS Registry
Finally, starting your PQRS submission when it’s fresh in your mind is never a bad idea. While in 2015 at Mingle Health, we were able to keep our registry open to help practices right up until the last day of the submission period, there’s no guarantee that will happen again.
Some registries have to close as they reach capacity with other practices and providers who also wait until the last minute to start reporting and some close as early as a month before the deadline. The easiest way to guarantee you’ll have a registry to help you report your data to CMS is to sign up before the submission period begins.
You can register to use PQRS Solutions™, a product of Mingle Health, right now. With PQRS Solutions you can use our Submission Dashboard™ to build your report one step at a time, and get help from our consultants, every step of the way. Not ready to get started? Contact us today for a free consultation.
Dr. Dan Mingle shares key changes to MIPS from the 2019 Final Rule.