PQRS continues to evolve and the rules continue to change. The rules are spelled out in the Physician Fee Schedule (PFS) Final Rule published in December of the prior year. It’s a daunting document—dense, difficult to read and to follow as it contains not just the new rules, but all of the comments that have been sent in by stakeholders during the rulemaking process.
Each year at Mingle Health, we meticulously comb through the Final Rule to understand the implications for PQRS and for our clients. We present a Webinar each year that distills the information into the most important points. Links to our webinar slides and video on the 2015 PFS Final Rule are at the end of this post., There is a link as well to be notified about a webinar on the 2016 Final Rule when it is released in a few months.
Here are the highlights from the 2015 final rule:
Incentives are gone.
As of 2015, there are no incentives and the penalty has gone up. Starting with the 2015 service year eligible providers will face a 2% penalty for failing to submit PQRS, and, subsequently, eligible physicians will face an additional value-based modifier penalty of up to 4%.
Deadlines and Submission Methods change only slightly.
The deadline for registry submission for PQRS is March 31, 2016. There are no changes to submission methods, though the deadline for registering for GPRO is now June 30 annually. Read more about the advantages of GPRO here. CMS did state they don’t like the claims submission method and expect to phase it out at some point due to a high failure rate (I’ve written previously about the challenges of using the claims submission method).
Cross-cutting measures are a new requirement.
In addition to the requirement introduced in 2014 for nine measures in three domains, groups and eligible providers with at least one face-to-face encounter must include a cross-cutting measure. Review a list of 2015 cross-cutting measures here (Opens PDF in new window). If reporting fewer than nine measures under the Measure Applicability Validation (MAV) process, eligible providers may be exempt from the requirement if CMS reviews claims data and finds fewer than 15 eligible face-to-face encounters.
Quality and Resource Use Reports (QRUR) are your key to understanding how you fare with Quality Tiering under the Value-Based Modifier.
This report is available by tax ID number (TIN) and summarizes Medicare’s assessment of your quality and cost of care relative to other providers. Remember, the quality tiering adjustment under the value-based modifier (VBM) rewards high-quality, low-cost care (performing above average by at least one standard deviation) and penalizes low-quality, high-cost care. Expect to see select data from this report increasingly made available to the public via the Physician Compare website.
The full 2015 Medicare PFS Final Rule is available on CMS’ website. Here are the slides from our webinar about the 2015 Medicare PFS Final Rule:
<Need Slideshare Link and Vimeo Link>- recommend linking to resources
Looking to get started with PQRS? Our team at PQRS Solutions is here to help and we want to be your trusted partner. Contact us today.
To learn more, check out our upcoming and on-demand webinars.
Have a question? My team and I are here to help. Please post your questions in the comments below, or contact us.
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