Last week, we covered the registry-and claims-based reporting methods for PQRS. In this post, I’ll discuss the complexities associated with reporting PQRS using the Group Practice Reporting Option (GPRO). In past years, GPRO seemed to be the most practical option for practices with more than two eligible professionals. This year, however, Medicare added more stipulations to the GPRO program—and in some cases, those add-ons might make the whole thing more trouble than it’s worth.
The Basics of GPRO
- GPRO is available to clinics with two or more eligible professionals all of whom operate under the same tax ID, or TIN.
- To report using GPRO, your clinic must self-nominate through CMS. In 2014, nomination was not open until April, and this year’s nomination will probably open around the same time. For those who would prefer to get a jump-start on fulfilling their reporting requirements, that delay could be pretty frustrating.
- The main difference between GPRO and individual reporting is that the eligible professionals in the participating practice are able to meet the requirements for satisfactory reporting together—meaning each individual therapist does not necessarily have to report on 50% of his or her patients. For example, in a practice with two eligible therapist, the first therapist could report on 40% of his or her patients, and the second therapist could report on 60% of his or her patients.
Three Ways to Report
- The first reporting method available to 2015 GPRO participants is essentially the same as the individual submissions process. That is, the participating practice must report nine measures for at least 50% of their Medicare Part B FFS (fee-for-service) patients. These measures must cover at least three NQS domains, and at least one measure must qualify as a cross-cutting measure.
- With the second option, practices must report six measures across two NQS domains for at least 50% of its Medicare Part B FFS patients, and it must conduct Consumer Assessment of Healthcare Providers and Systems (CAHPS) survey using a CMS-certified survey vendor. The certified vendor will administer a patient satisfaction survey on the participating practice’s behalf and aggregate the data. Please note that the practices are responsible for the cost associated with conducting these surveys.
- Finally, some practices have the option of using CMS’s GPRO Web Interface. The specifics on this option are still a bit fuzzy, but here’s what we know:
- With this option, groups must report on all measures included in the interface for their first 248 Medicare Part B patients. If they have fewer than 248 Medicare patients, then they must report on at least one measure for 100% of their Medicare Part B patients.
- Only practices with 25 or more eligible professionals can report via the GPRO Web Interface.
- As of now, practices that use the interface are not subject to the MAV process. However, this could change.
- Using the interface could prove arduous as it requires double-data entry (i.e., you must manually enter all of your patient information).
If you have 100 or more eligible professionals participating in GPRO—regardless of which GPRO reporting method you choose—you must also add the CAHPS survey component.
Although your clinic’s optimal GPRO method will depend on your specialties, number of eligible professionals, payer mix, and applicable measures, generally speaking, GPRO option number one appears to be the simplest. It’s also the one supported by WebPT’s registry-based PQRS service.
If you choose GPRO option number two, it’ll cost you—literally, you’ll have to pay a third-party organization to administer the CAHPS survey. And on top of the financial burden of the survey, it’s on you to actually find a CMS-certified vendor to conduct it. So, if you’re a practice with more than 100 eligible professionals—meaning you’re required to conduct a CAHPS survey if you wish to report as a group—then you might want to consider the pros and cons, including the financial burden, of GPRO versus individual submission.
The Web Interface method also has some drawbacks. First of all, it’s only open to clinics with at least 25 eligible professionals. On top of that, the rules regarding the number of measures you’re required to report are murky at best. And worst of all, it requires double data-entry—meaning you have to input patient information into your registry, and then again into the Web Interface.
Is your practice considering participating in PQRS using GPRO? What questions or concerns do you have? Leave ’em in the comments section below.