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Today's blog post comes from writers Charlotte Bohnett, Brook Andrus, and Erica Cohen as well as WebPT Founder and COO Heidi Jannenga, PT.

Last Wednesday, just before we all headed home to gorge ourselves on turkey and pumpkin pie, Medicare released the Final Rule—all 1,369 pages of it. While it wasn’t exactly light reading, our fearless leader (and speed reader) Heidi Jannenga pored over this hefty document with a mission of finding all the Physician Quality Reporting System (PQRS) information that’s most important to you right now. Below is a breakdown of what you need to know about PQRS 2014.

1.) There are a lot of measures.
We’re talking gobs of measures. Open the Final Rule, head to page 832, and start scrolling. Here are the ones that apply to rehab therapists (and that WebPT currently has or will have in the application):

PT:

  • #126 Diabetes Foot/Ankle Evaluation (Registry only)
  • #127 Diabetes - Footwear Evaluation (Registry only)
  • #128 BMI screening
  • #130 Current Medications
  • #131 Pain Assessment
  • #154 Falls Risk Assessment
  • #155 Falls POC
  • #182 Functional Outcome Assessment
  • #245 Chronic Wound Care
  • Back Pain Measure Group (See the next section)

OT:

  • #128 BMI screening
  • #130 Current Medications
  • #131 Pain Assessment
  • #154 Falls Risk Assessment
  • #155 Falls POC
  • #134 Preventative Screening Clinical Depression
  • #173 Alcohol consumption Assessment (Registry only)
  • #181 Elderly Maltreatment Screen and Follow-Up
  • #182 Functional Outcome Assessment
  • #226 Tobacco Use Screen and Cessation Intervention

SLP:

  • #130 Current Medications

Outside of WebPT, there are also FOTO’s Functional Deficit Measures:

  • #217 Change in Risk-Adjusted Functional Status for Patients with Knee Impairments
  • #218 Change in Risk-Adjusted Functional Status for Patients with Hip Impairments
  • #219 Change in Risk-Adjusted Functional Status for Patients with Lower Leg, Foot or Ankle Impairments
  • #220 Change in Risk-Adjusted Functional Status for Patients with Lumbar Spine Impairments
  • #221 Change in Risk-Adjusted Functional Status for Patients with Shoulder Impairments
  • #222 Change in Risk-Adjusted Functional Status for Patients with Elbow, Wrist or Hand Impairments
  • #223 Change in Risk-Adjusted Functional Status for Patients with Neck, Cranium, Mandible, Thoracic Spine, Ribs or Other General Orthopedic Impairments

2.) There are also measures groups.
CMS defines a measures group as “a subset of four or more PQRS measures that have a particular clinical condition or focus in common. The denominator definition and coding of the measures group identifies the condition or focus that is shared across the measures within a particular measures group.” Individual eligible professionals have a slew of group measures to report on; however, rehab therapists only qualify to report on the back pain measures group. (See Table 61 below.)

You can only report on group measures via registry, and you must report all four during the initial evaluation. In past years, such measures were not available in WebPT, but we’re adding the back pain measures group to our registry-based measures for 2014. Contrary to past years, this measure selection is now the easiest route to avoid the penalty and obtain the incentive (see details below to learn how).

3.) There is a 2% penalty for noncompliance.
CMS is upping the penalty ante this coming year, implementing a 2% payment adjustment (assessed in 2016) for not satisfactorily completing PQRS in 2014. For reference, the penalty for not satisfactorily completing PQRS in 2013 was a 1.5% payment adjustment. So how do you avoid the 2016 penalty?

Individual Claims-Based

1.) Report at least three measures on at least 50% of your Medicare Part B FFS patients.

Or

2.) If fewer than three measures apply to you as the eligible professional, then report one to two measures on at least 50% of your Medicare Part B FFS patients.

  • According to the Final Rule, this route is “subject to the Measures Applicability Validation (MAV) process, which would allow [Medicare] to determine whether an eligible professional should have reported quality data codes for additional measures and/or covering additional NQS domains.”
  • For claims-based reporting, there are two measures for chiropractors and only one for SLPs. Thus, these eligible professionals will automatically go through the MAV process.

Note that CMS will not count any measures with a 0% performance rate.

Individual Registry-Based

1.) Report at least three measures covering at least one NQS domain on at least 50% of your Medicare Part B FFS patients.

Or

2.) If fewer than three measures covering at least one NQS domain apply to you as the eligible professional, then report one to two measures covering one NQS domain on at least 50% of your Medicare Part B FFS patients.

  • According to the Final Rule, this route is “subject to the MAV process, which would allow [Medicare] to determine whether an eligible professional should have reported quality data codes for additional measures and/or covering additional NQS domains.”
  • For registry-based reporting, there are two measures for chiropractors and one for SLPs. Thus, these eligible professionals will automatically go through the MAV process.

Note that CMS will not count any measures with a 0% performance rate.

Individual Measures Groups (Registry Only)

1.) Report at least one measures group, and report each measures group for at least 20 patients.

GPRO (Registry Only, Two or More Eligible Professionals)

1.) Report at least three individual measures covering at least one of the NQS domains.

Or

2.) If fewer than three measures covering one NQS domain apply to the group practice, report one to two measures covering one NQS domain on at least 50% of the group practice’s Medicare Part B FFS patients.

  • According to the Final Rule, group practices that report fewer than three measures covering one NQS domain via the registry-based reporting mechanism will be “subject to the MAV process, which would allow [Medicare] to determine whether a group practice should have reported on additional measures.”
  • GPRO is a registry-based reporting option, so the same number of measures available is the same as individual registry-based reporting: ten for PTs, nine for OTs, one for SLPs, and two for chiropractors. Thus, chiropractors and SLPs will need to go through the MAV process.

Note that CMS will not count any measures with a 0% performance rate.

4.) There is a 0.5% incentive for successfully reporting.
Just like in 2013, there is a 0.5% incentive for successfully completing PQRS. How do you do that?

Individual Claims-Based

1.) Report at least nine measures covering at least three National Quality Standard (NQS) domains on at least 50% of your Medicare Part B fee-for-service (FFS) patients.

Or

2.) If fewer than nine measures covering at least three NQS domains apply to you as the eligible professional, then report one to eight measures covering one to three NQS domains, and report each measure on at least 50% of your Medicare Part B FFS patients.

  • According to the Final Rule, this route is “subject to the Measures Applicability Validation (MAV) process, which would allow [Medicare] to determine whether an eligible professional should have reported quality data codes for additional measures and/or covering additional NQS domains.”
  • For claims-based reporting, there are only eight individual measure options for PTs and OTs, one for SLPs, and two for chiropractors. Thus, these eligible professionals will automatically go through the MAV process.

Note that CMS will not count any measures with a 0% performance rate.

Individual Registry-Based

1.) Report at least nine measures covering at least three NQS domains on at least 50% of your Medicare Part B FFS patients.

Or

2.) If fewer than nine measures covering at least three NQS domains apply to you as the eligible professional, then report one to eight measures covering one to three NQS domains on at least 50% of your Medicare Part B FFS patients.

  • According to the Final Rule, this route is “subject to the MAV process, which would allow [Medicare] to determine whether an eligible professional should have reported quality data codes for additional measures and/or covering additional NQS domains.”
  • For registry-based reporting, there are ten measure options for PTs, nine for OTs, one for SLPs, and two for chiropractors. Thus, SLPs and chiropractors will automatically go through the MAV process, while PTs and OTs can obtain the incentive without MAV.

Note that CMS will not count any measures with a 0% performance rate.

Individual Measures Groups (Registry Only)

1.) Report at least one measures group, and report each measures group for at least 20 patients, a majority of whom must be Medicare Part B FFS patients.

 

  • OTs, SLPs, and chiropractors are not eligible for this option. However, PTs can use it to both meet the criteria for the incentive and to avoid the penalty.

GPRO (Registry Only, Two or More Eligible Professionals)

1.) Report at least nine measures covering at least three of the NQS domains.

Or

2.) If fewer than nine measures covering at least three NQS domains apply to you as the eligible professional, then report one to eight measures covering one to three NQS domains for which there is Medicare patient data on at least 50% of the group practice’s Medicare Part B FFS patients.

  • According to the Final Rule, this route is “subject to the MAV process, which would allow [Medicare] to determine whether a group practice should have reported on additional measures and/or measures covering additional NQS domains.”
  • GPRO is a registry-based reporting option, so the same number of measures available is the same as individual registry-based reporting: ten for PTs, nine for OTs, one for SLPs, and two for chiropractors. PTs also have the option to report on the measures group for back pain. This allows PTs to be eligible for the incentive without going through the MAV process.

Note that CMS will not count any measures with a 0% performance rate.

5.) Medicare wants you to use registry-based reporting.
Combing through the Final Rule, we found many references to Medicare’s intentions to continue beefing up PQRS requirements more and more each year. We believe their goal is to drive all eligible professionals toward registry-based reporting. After all, it’s much easier to collect data from PQRS registries than from individually submitted claim forms. The document states: “It is our intent to ramp up the criteria for satisfactory reporting for the 2017 PQRS payment adjustment to be on par or more stringent than the criteria for satisfactory reporting for the 2014 PQRS incentive.” In other words, you can expect the 2015 requirements for avoiding the penalty to be similar to the 2014 requirements for receiving the incentive (i.e., reporting on nine measures).

Furthermore, despite receiving many negative comments regarding the steep increase in the number of measures eligible professionals must report, CMS is sticking to their guns: “...since the PQRS program has provided incentives for satisfactory reporting since 2007, we believe it is appropriate to increase the number of measures to be reported via claims from three measures covering one NQS domain to nine measures covering three NQS domains for the 2014 PQRS incentive. We believe six years is enough time for eligible professionals to familiarize themselves with the reporting options for satisfactory reporting under the PQRS.”

And the last context clue we found in favor of registry-based reporting is perhaps the strongest: “We believe our interest in aligning the satisfactory reporting criteria of individual measures via claims with the satisfactory reporting criteria of individual measures via EHR for the 2014 PQRS incentive outweighs the need for such a gradual increase in the number of measures required to be reported via claims.” To put it succinctly, Medicare isn’t cutting claims-based reporters any slack. It’s easier to report via a registry (typically through an EMR or EHR), and it’s more convenient for Medicare. Thus, the more they can prod you toward registry-based reporting, the better. It’s our theory (and the Proposed Rule mentioned it) that eventually Medicare will do away with claims-based reporting entirely.

Well, wasn’t that a hearty pill to swallow? But it’s definitely a more palatable pill than the original 1,369 page document. Now that we’ve nailed down all the PQRS rules for 2014, it’s time to ensure your clinic is prepared, and we can help. Register now for our special PQRS webinar on December 20. (Curious about WebPT’s PQRS solution? Email us at membervalue@webpt.com.)

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