Frequently Asked Questions - 2016 PQRS Registry

PQRSPROTM empowers CMS eligible professionals to benefit from the clinical review and to avoid the -2% Payment Adjustment to be leveraged in 2018 on providers who do participate in 2016 PQRS reporting; offering individual registry reporting and the registry-based Group Practice Reporting Option (GPRO) for practices of 2 or more operating under one Tax ID Number (TIN).

Healthmonix, the development team behind PQRSPRO incorporates insights and experience gained over years as a solution provider to medical specialty societies, academies, boards, and CME offices – and as a qualified PQRS Registry since 2009 – to report 2016 PQRS data to CMS. We have helped thousands of providers meet their reporting goals - with an over 99.5% success rate!

Q. What are the “PQRS Reporting Rate” and “Performance Rate?

The “PQRS Reporting Rate” is the percentage of times that all of the applicable questions for a specific measure were answered, compared to the number of eligible patient visits for that measure (i.e., reporting 50% of all eligible patient visits for individual measures).

The “Performance Rate” is the percentage of times that you met the measure compared to the number of eligible patient visits entered for that measure and how many times you could have met the measure (i.e., 100 patient visits, 75 met, 25 not met = 75% performance rate).

For Individual Measures reporting, you must have minimum of 50% reporting rate of your eligible patient visits for each of the measures chosen. This 50% does not relate to either the “reporting” or “performance” rates. The registry does not know the total number of eligible patient visits your practice had for the year, so we have no way of calculating this percentage.

Performance rate must be over 0% to be submitted (in other words, you need to meet the measure at least once to report successfully). See next question.

Q. Do I need to meet the measures in order to qualify for the PQRS incentive? What is the Zero Performance Rule?

CMS altered the original “pay for reporting” model of PQRS in 2011, requiring that each measure reported be met at least once (no 0% reporting).

The only 2 exceptions to this “Zero Performance Rule” are:

1) when reporting all exclusions on the measure (as in a recorded system or patient reason, valid explanation, or other justification for not meeting the measure that is allowed for the measure), keeping in mind that 3% of all PQRS participants are subject to audit.

2) when the measure is an 'inverse' or 'reverse' performance measure (lower percentage is better), and in this case, you cannot submit a 100% performance rate.

Q. When should I sign up for 2016 participation?

A. You can register any time until the end of January 2017!  If you are reporting individual measures that require 50% reporting, you may wish to get started early, enter data from the portion of 2016 that has already passed, and then continue throughout the year to complete the submission.  You will need to complete your submission by February 1, 2017.

Measures Groups require entry of only 20 patient visits and may be completed at any time during the year.

Q. How do I select the measures to report?

A. To determine the best measures to report in your situation, review the available Measures Groups and Individual Measures and choose the best option(s), based upon your specialty, patient population, and practice considerations.

Contact us if you have any questions.

Q. What is the future of the PQRS program and why should I participate?

A. It's advisable to get started with PQRS reporting as soon as possible in order to fully prepare for the future of the program:

  • In 2016, eligible professionals who do not satisfactorily report PQRS will be subjected to a -2%  payment adjustment (penalty) in the 2018 fee schedule.
  • Physician practices of any size under the same Tax ID Number (TIN) are also subject to upward, neutral, or downward adjustments through the pay-for-performance 'quality-tiering' methodology of the Value-Based Payment Modifier (VBPM) (leveraged in 2018 and based on 2016 PQRS performance). The loss of revenue can add up!
  • In addition, participants' basic contact, demographic and historical information is listed on the CMS Physician Compare website, which will also begin displaying performance metrics.
  • By participating in PQRS, providers have the opportunity to contribute to the expansion and use of evidence-based and consensus quality practices supported widely across specialties and by CMS.

Q. My practice is participating in Meaningful Use and already submitting eCQMs.  Do I need to participate in PQRS also?

A. Yes!  PQRS must be reported in addition to MU in order to avoid the 2018 2% non-reporting penalty and associated Value Modifier penalties. PQRS and Meaningful Use are separate CMS programs, with differing requirements, rules and (in some cases) Clinical Quality Measures (CQMs). There is some alignment between the programs, as many MU-participating EHRs also report PQRS measures.  If you are reporting MU through your EHR, contact them to inquire.

More information is available on the CMS Meaningful Use page.

Q. What are the different ways to submit data for PQRS?

A. Quoting CMS, “individual eligible professionals may choose to report information on individual Physician Quality Reporting quality measures:
        (1) to CMS on their Medicare Part B claims,
        (2) to a qualified Physician Quality Reporting registry, or
        (3) to CMS via a qualified electronic health record (EHR) product, or
        (4) to a qualified Physician Quality Reporting data submission vendor (DSV), or
        (5) to a qualified Quality Clinical Data Registry.

Individual eligible professionals who meet the criteria for satisfactory submission of Physician Quality Reporting quality measures data via one of the reporting mechanisms above for services furnished during a 2016 reporting year will qualify to avoid the 2018 payment adjustment.”

CMS offers updates and information on their website here, provides downloads and further information here, and educational resources here.

Q. What are the advantages of registry-based reporting?

A. There are many advantages to using Healthmonix's PQRSPRO Registry:

  • PQRSPRO will accept and validate your 2016 PQRS data throughout the year, or all at once, so there is no need to track claims. Once registered, you can enter all of your data from January 1, 2016 forward. You can start any time!
  • The PQRSPRO reporting process increases the value of your data, with free, integrated performance and validation and results calculation reports for assessing your practice to identify potential areas of improvement. Reports may also be used to take advantage of other private insurance incentives and discounts.
  • Some measures are “registry only” measures and can be reported only through a qualified CMS PQRS registry
  • PQRSPRO offers thorough data review, analysis, and submission.1  Comprehensive reports help to understand the calculated measures and ensure there is not a 0% performance rate.
    • The system is easy to use and can be completed efficiently.
    • Raises the potential for meeting PQRS reporting criteria and avoiding the 2018 -2% Payment Adjustment for nonparticipation in 2016.
    • Eliminates the need to track G codes or worry about making mistakes in claims-based reporting.
    • CMS analyses have demonstrated that providers were significantly more likely to successfully report than claims-based reporting.
    • Along with Healthmonix's enhanced data validation, PQRSPROTM is the logical choice!

Q. Is PQRS applicable to Railroad Medicare, Medicare Advantage or to Medicaid patients?

A. Reporting is only required for patients with primary or secondary Medicare Part B FFS (Fee-for-service) or Railroad Medicare insurance.  It is not applicable to Medicare Advantage, replacement, or Medicaid patients.  PQRSPRO will collect quality data, calculating measures to ensure incentive eligibility.

Q. Does an entire practice have to participate in PQRS?

A. No, this is still a voluntary program - but does carry penalties for non-reporting. For 2016 PQRS reporting, it's advisable for all eligible professionals in a practice to report PQRS to avoid the -2% Payment Adjustment in 2018 for nonparticipation in 2016. 

Unless pursuing GPRO (see below), registry reporting is completed by separate data submission for individual providers. They can be considered incentive eligible even if other providers at a practice do not participate.  Providers in a group must submit using their individual NPI number (the NPI number for the Rendering Provider on line 24J of claims), and not the group NPI.

If you are interested in the Group Practice Reporting Option - GPRO, which is applied to an entire practice, under the Group’s Tax ID Number (TIN) you must register/self-nominate with CMS from April 1, 2016 and take note that the deadline for GPRO registration is June 30, 2016!

Q. Can I use my group NPI number for submitting data? It is always on the claim forms.

A. The incentive bonus is calculated on allowed claims for the reporting  period submitted with the combination of individual NPI number and Tax ID (TIN).  For individual provider reporting, you MUST use your individual NPI number, which is on the claim form as the Rendering Physician on line 24J of claims, in order to succeed in your submission of PQRS data to CMS.

Q. What measures can be reported for 2016?

A. PQRSPRO supports ALL PQRS 2016 registry Measures Groups and Individual Measures, but only those applicable to mental health professionals are outlined on this site. The CMS measures specification list can be found here. The PQRSPRO list can be found here.

Note: Beginning in 2014, Measures Group reporting can ONLY be accomplished electronically and is not available through the claims-based option.

Q. How are measures reported?

A. There are 4 forms of reporting available through PQRSPRO

  • Measures Groups, which require the entry of 20 unique patient charts (11 of which have to be Medicare Part B FFS patients).
  • Individual Measures Reporting - choose at least 9 individual measures from at least 3 National Quality Strategy (NQS) domains and report at least 50% of the applicable Medicare patient visits.
  • Payment Adjustment Avoidance, which allows the reporting of at least 3 measures and 50% of eligible patient visits in order to avoid the 2018 -2% payment adjustment – (but not gain the incentive) for 2016 PQRS reporting.
  • GPRO (Group Practice Reporting Option) (click for more information) which is available to groups of 2 or more operating under a single TIN and the same reporting requirements as Individual Measures Reporting, but applied to a group practice. Contact us if you are interested in GPRO.

Note each measure reported must be met at least once (no 0% reporting).

The only 2 exceptions to this “Zero Performance Rule” are:

  1. 1) when reporting all exclusions on the measure (as in a recorded system or patient reason, valid explanation, or other justification for not meeting the measure), keeping in mind that 3% of all PQRS participants are subject to audit.
  2. 2) when the measure is an 'inverse' performance measure (lower percentage is better), and in this case, you cannot submit a 100% performance rate.

Q. What if there is not a Measures Group or 9 Individual Measures applicable and reportable from my practice?

A. If your patient population/practice does not meet the required criteria for reporting 9 individual measures from 3 NQS domains, reporting 1-8 measures is subject to the Measures Applicability Validation (MAV) process, which allows CMS to apply a ‘clinical relation/domain test’ – comparing ‘clusters’ or sets of closely related measures to determine whether additional measures and/or domains may have also been applicable.

If CMS analysis determines there are no other measures that should have been reported then you will be eligible to receive a Physician Quality Reporting financial incentive. If CMS finds that there are additional measures applicable for that reporting period, you will not be eligible for a PQRS incentive payment.

We recommend that you read CMS’s information on the MAV process before selecting your measures. Please direct any questions on the MAV process to CMS via the QualityNet Help Desk phone: 866.288.8912 email: qnetsupport@hcqis.org

Q. If I have fewer than 9 Individual Measures applicable to my practice, should attempt to report on measures that may not be relevant to the practice?

A. No. Providers should only report on measures that are applicable to their patients and practices. If there are less than nine (9) quality measures applicable to the services provided each measure must be reported for at least 50% of the patient visits in which the measure was reportable. The MAV process, described above, will apply.

Q. What will be included in the data submission to CMS?

The PQRSPRO Registry provides CMS with the required calculations of reporting and performance rates for the selected PQRS measures for that provider, using the combined NPI / TIN as the identifier. Individual patient information is de-identified in the system and not submitted to CMS.

Q. What time period is reported for PQRS?

A. For Individual Measures Reporting in 2016, Eligible Professionals (EPs) must report at least 50% of all eligible Medicare patient visits for the entire 12-month period (January 1, 2016- December 31, 2016). For Measures Group Reporting in 2016, at least 20 patient visits (11 of which must be Medicare) that occurred within the 2016 reporting year are reported.

Q. If I also submitted claims-based data to CMS for 2016 PQRS, can PQRSPRO be used for 2016 reporting?

A. Yes!  CMS makes incentive payment decisions based on the most complete data set received. But CMS will not combine the data from the 2 methods.  For Individual Measures Reporting, you must submit data for 50% of your applicable patients from the entire Medicare patient population through the registry for accuracy.

Q. What will I receive from CMS?

A. If you provided PQRSPRO with an email address, you will receive a feedback report with the results of your PQRS submission from CMS via email in the fall of 2017. Physician Quality Reporting System participants will not receive claim-level details in feedback reports.

MIPPA (The Medicare Improvements for Patients and Providers Act) also required CMS to post the names of eligible professionals and group practices who satisfactorily report to the PQRS program on a publicly available website.  This information is now posted on the Medicare Physician Compare website.

top

CMS Links & References

2016 PQRS Documents on CMS

2016 PQRS How to get Started

Analysis and Payment

(zip file, bottom of page 2016 PQRS Registry Measure Applicability Validation outlines the process and the 2016 PQRS clinically related domain clusters)

Value-Based Payment Modifier

Medicare Physician Compare

CMS Help Desk Resources

QualityNet Help Desk – 7:00 AM – 7:00 PM CT

Phone: 866.288.8912

Email: qnetsupport@hcqis.org

URL: https://www.qualitynet.org

Contact QualityNet for: General CMS PQRS & E-Prescribing information, PQRS Portal password issues & PQRS feedback report availability and access.

More Questions? Contact us!

top

1 Submission of data to CMS is not a guarantee of CMS PQRS payment adjustment avoidance.
I want to compliment you and your colleagues for fine work.

Practice Administrator, Internal Medicine, Saint Augustine, FL

I've looked at all of them now and I'm convinced that yours is the best registry. So professional, so simple to use and backed by knowledgeable, personal support. I'm confident that I'll get PQRS reporting right!

Private Group Practice, Colorado

This is an intuitive interface that gathers just the info you need and nothing more. Whoever put it together had a good understanding of the info needed and how to set it up logically.

Physician, General Practice Network, Greensboro, NC

I recommended this solution to my colleagues and they're signing up too!

Physician Assistant, Family Care Group Practices, Chicago, IL

FYI, we did get a nice check from CMS (over $20,000!) so it is well worthwhile.

University of Pennsylvania

"I didn't know that I could have it any better. Somebody needs to let others know about all of the benefits of PQRSPRO!"

RN/Coder, Private Cardiology Practice

About 80% of our patient populate are Medicare, so CMS PQRS program incentives have been very lucrative for us.

RN/Coder, Private Cardiology Practice

We used a popular, more expensive PQRS Registry last year and had issues with the website but could not get anyone on the phone and had to leave voicemail and follow-up with an email.  For the money that we paid, they should have better customer service. PQRSPRO customer service is a Rolls Royce compared to the Volkswagen I experienced last year. When I called, I spoke to someone right away!

RN/Coder, Private Cardiology Practice

The PQRSPRO Registry system was easier to use than the other one.  Chart abstraction was simple and easy to understand and all measure questions were asked at once.  The other system made me wait for a prompt to move on once I answered one question – a much slower process.

RN/Coder, Private Cardiology Practice

The cost of PQRSPRO is much more reasonable than any other!

RN/Coder, Private Cardiology Practice

The final measure report was great and will also be useful for submitting to our malpractice insurance carrier to qualify for a discounted premium rate.

RN/Coder, Private Cardiology Practice

Users reported receiving up to $70,000 from participation in 2010 via our system.

President, Healthmonix

We are very happy with you and your company. Thank you for all of you efforts.

After trying for a couple years to receive the bonus, we finally received it this year using your system.

Your support has been awesome!

I wish we would've known about you three years ago! This was a breeze!

Group Cardiology Practice, Illinois

We are very satisfied with your process and service and confident that our practice will benefit from the incentive and avoid the penalties.

Intern, Ophthalmology Practice

CMS Disclaimer

If reporting for Physician Quality Reporting System (PQRS) through another Centers for Medicare and Medicaid Services’ (CMS) program (such as the Medicare Shared Savings Program, Comprehensive Primary Care Initiative, Pioneer Accountable Care Organizations), please check the program’s requirements for information on how to report quality data to earn a PQRS incentive and/or avoid the PQRS payment adjustment.

Please note, although CMS has attempted to align or adopt similar reporting requirements across programs, eligible professionals (EPs) should look to the respective quality program to ensure they satisfy the PQRS, Electronic Health Record (EHR) Incentive Program, Value-based Payment Modifier (VM), etc. requirements of each of these programs.

You should not select that you participate in the Medicare PQRS-EHR Incentive Pilot when you attest to this question on the CMS website. The Healthmonix Registry is NOT a qualified submission vendor for clinical quality measures for purposes of meaningful use.