Should I participate in PQRS?
Is it too late for 2014?
What does it take?
You should participate in PQRS. There are still incentive dollars to be earned and, starting with 2013, penalties are already in effect if you don’t report.
Registry submissions begin January 1 and must be complete by March 15, 2015.
No matter what your circumstances, you should be able to make a submission with only a modest effort and investment. Review below, the many options for submission.
The Gold Standard of all PQRS submissions utilizes Practice Management System data and Electronic Health Record Data.
To participate at this level YOU NEED TO BE ABLE TO PROVIDE
Practice Management data The practice management data holds the key to eligibility for measures. You give us data in flat file or spreadsheet format identifying provider, patient, date of service, charge codes, diagnosis codes, and key modifiers. Options include:
- Run a canned report from your Practice Management System if an adequate report exists.
- Provide a report direct from the practice management system database if you have access to the reporting skills required.
- Get your billing company to run the report for you.
- Give us access to your practice management system database to extract the data for you.
Electronic Health Record data
The EHR holds the clinical data necessary to determine the performance on each measures.
As your PQRS Vendor, we provide the following services:
We receive and process your Practice Management System data for two purposes
- We calculate your expected incentive and penalty based on your actual services to determine if it is worth your time and effort to make a submission this year.
- We consider the Practice Management System Billing data to be the “Source of Truth” to identify patients that need to be reported for each provider for each measure. A submission using billing data to identify reportable patients is nearly bulletproof and should survive any level of scrutiny by Medicare.
We extract your performance data directly from the Electronic Health Record.
- Patient-specific data is extracted from the Electronic Health Record. The extract is limited to Medicare patients and whittled down as far as is practical to the minimum necessary data set
We determine numerators, denominators, and performance rates from the submitted data and determine incentive eligibility.
What if I have a paper Record?
You can make a registry submission.
If you are eligible for one of the measures groups you will be able to audit between 20 charts, answering 4-10 questions per chart, enter your data on our website and complete your submission in less than an hour.
If you are not eligible for a measure group, we can identify the eligible patients and help you choose three measures that will require a small number of chart audits.
What if I have Electronic Health Record data, but I can’t provide Practice Management System Data?
We can estimate your return on investment based on specialty specific national averages.
We can assess patient measure eligibility from electronic health record data. It’s not as accurate as Practice management data. There is a small risk that incentive eligibility would not survive Medicare audit. But Medicare has, so far, been inclined to accept EHR data as a reasonable proxy of the billing data.
What if I can provide Practice Management System data but cannot provide access to my Electronic Health Record data?
You will treat your EHR as if it were a paper chart
What if I have a paper record and I cannot provide Practice Management system data?
If you are eligible for a group measure, and you can identify from memory 30 patients who qualify for the measure, you can audit those 30 patient charts. We can build a submission for you from the summary spreadsheet you will provide to us.
What if I have started to build a claims submission but failed to complete it?
We can turn a claims submission for you into a registry submission. If you can provide Practice Management data to us:
We can extract the codes you have already entered for your claims submission.
We can identify the deficiencies and help you turn a failed claims submission into a successful registry submission by abstracting only the patient charts that you did not address through claims during a visit.
There is pretty much a method for every circumstance.
Dr. Dan Mingle and members of the team share their insights on how to maximize your success and payments for MIPS and APMs.