In the spirit of the season, today we give thanks for Medicare’s brand new Final Rule. Drier than overcooked turkey, we decided to carve up this bird into the most pertinent chunks of Physician Quality Reporting System (PQRS) information for you and your practice so you don’t have to. Here’s what you need to know about PQRS 2015:

Measures, Measures, Measures

Medicare likes measures––225 of them to be exact––and they don’t care who knows. Thankfully, all of the individual quality measures that applied to rehab therapists in 2014 also apply in 2015––except for the Back Pain Measures Group, but we’ll get to that later. Stay tuned to the WebPT Blog, because later on this month, we’ll detail all of the measures available to PTs, OTs, and SLPs (as well as those available within WebPT).

Cross-Cutting Measures

New for 2015, cross-cutting measures are part of Medicare’s mission to obtain “a better picture of the overall quality of care furnished by eligible professionals, particularly for the purpose of having PQRS reporting being used to assess quality performance under the VM [value-based modifier].” CMS feels that requiring eligible professionals to report on “broadly applicable, cross-cutting measures will provide...quality data on more varied aspects of an eligible professional’s practice.”

If you’re an eligible professional who sees at least one Medicare patient in a billed visit during 2015, then you must report on at least one cross-cutting measure to meet satisfactory reporting requirements. Fair warning: Medicare hopes to require more cross-cutting measures in the future––but for now, one measure will suffice.

Fortunately, the cross-cutting measure requirement is not in addition to your regular reporting. There are five existing individual quality measures for rehab therapists that are included on the cross-cutting measures list (for the full list, see page 718 of the Final Rule):

  • #128 BMI screening
  • #130 Current Medications
  • #131 Pain Assessment
  • #134 Preventative Screening Clinical Depression
  • #182 Functional Outcome Assessment

Bye-Bye, Back Pain Measures Group

See, I told you we’d come back to this. Here’s the deal: CMS removed six measures groups from the list of available reporting options in 2015, including the Back Pain Measures Group––the only one for which physical therapists could qualify. CMS believes that “the measures in this measure group reflect clinical concepts that do not add clinical value to PQRS. Specifically, the measures in this group are entirely clinical process measures that do not meaningfully contribute to improved patient outcomes.”

None of the measures groups available for 2015 apply to physical therapists or speech-language pathologists—which means PTs and SLPs cannot fulfill PQRS requirements by reporting on a measures group. Their only options for reporting are now individual submission and GPRO. For OTs, however, the dementia measures group, which consists of measures #47 and #280 through #288, is available in 2015. 

No Incentive for 2015

In addition to nixing the Back Pain Measures Group, CMS also has eliminated the 0.5% incentive for successfully completing PQRS. But that doesn’t mean reporting will get any easier. In fact, CMS has “ramp[ed] up the criteria for satisfactory reporting for the 2017 PQRS payment adjustment,” stating that they believe they have “provided the public with adequate time to prepare for reporting criteria that requires the reporting of 9 measures"—when nine measures apply to an eligible professional, that is (more on that later).

2% Penalty for Noncompliance

The penalty for failing to satisfactorily complete PQRS reporting in 2015 is the same as it was in 2014—that is, a 2% payment adjustment that will be assessed in 2017. Yikes! Here’s how to avoid it (if you reported to earn the incentive last year, the new requirements will be very familiar to you):

Individual Claims-Based
  • You must report on nine measures across three NQS domains for at least 50% of your Medicare Part B FFS patients.
  • If fewer than nine measures apply to you as an eligible professional, you must report on all the measures available to you (up to eight measures) for at least 50% of your Medicare Part B FFS patients. Here’s the breakdown of the number of applicable measures for each specialty:
    • PTs: Six measures
    • OTs: Nine measures
    • SLPs: One measure
  • When fewer than nine measures covering three NQS domains are reported, eligible professionals are subject to Medicare’s Measures Applicability Validation (MAV) process, which will “allow [Medicare] to determine whether an eligible professional should have reported quality data codes for additional measures.” So, if you are a PT or SLP, you’ll automatically go through the MAV process.
  • If you see at least one Medicare patient in a billed visit during 2015, then you must report on at least one cross-cutting measure, even if fewer than nine measures apply to you as an eligible professional.
  • CMS will not count any measures with a 0% performance rate.
Individual Registry-Based
  • You must report on nine measures across three NQS domains for at least 50% of your Medicare Part B FFS patients.
  • If fewer than nine measures apply to you as an eligible professional, you must report on all the measures available to you (up to eight measures) for at least 50% of your Medicare Part B FFS patients. Here’s the breakdown of the number of applicable measures for each specialty:
    • PTs: Eight measures
    • OTs: Ten measures
    • SLPs: One measure
  • When fewer than nine measures covering three NQS domains are reported, eligible professionals are subject to Medicare’s Measures Applicability Validation (MAV) process, which will “allow [Medicare] to determine whether an eligible professional should have reported quality data codes for additional measures.” So, if you’re an SLP, you’ll automatically go through the MAV process.
  • If you see at least one Medicare patient in a billed visit during 2015, then you must report on at least one cross-cutting measure, even if fewer than nine measures apply to you as an eligible professional.
  • CMS will not count any measures with a 0% performance rate.
GPRO (Registry Only, Available to Clinics with Two or More Eligible Professionals)

If the eligible professionals in your rehab therapy practice choose to participate in Medicare’s Group Practice Reporting Option (GPRO), you have two options for satisfactory reporting:

  1. Report on at least nine measures across three NQS domains for at least 50% of your Medicare Part B FFS patients.
     
    Or
  2. Report on six measures across two NQS domains, and complete a CAHPS survey. (Please note that this survey is required for groups with 100 or more eligible professionals.)

With both methods:

  • If fewer than nine (or six) measures apply, your group must report on all the measures available to you (up to eight measures) for at least 50% of your Medicare Part B FFS patients.
  • When fewer than nine (or six) measures covering three NQS domains are reported, the group practice is subject to the MAV process, which will “allow [Medicare] to determine whether a group practice should have reported quality data codes for additional measures.” So, if your group consists of only SLPs, it’ll automatically go through the MAV process.
  • If your group sees at least one Medicare patient in a billed visit during 2015, the group must report on at least one cross-cutting measure. The MAV process will not apply to cross-cutting measures.

There also is an option that allows some group practices to report using GPRO’s Web Interface. However, we don’t have all the specifics on this option yet. Here’s what we do know:

Groups with 25 or more—but fewer than 99—eligible professionals can report via the GPRO Web Interface. However, if your group chooses to go this route, there are some stipulations, including:

  • You must report on all measures included in the Web Interface for your first 248 Medicare Part B patients.
  • If you have fewer than 248 Medicare patients, you must report on at least one measure for 100% of your Medicare Part B patients.

For all GPRO options, CMS will not count any measures with a 0% performance rate.

Get Ready for Registry-Based Reporting

CMS is pulling no punches about its intent to move toward a purely registry-based system. So far, it seems like each year, the criteria for satisfactory reporting has become more stringent; and CMS has stated that it will “continue to eliminate measures available for reporting via claims.” Translation: it’s only going to get tougher for eligible professionals to comply with PQRS using the claims-based reporting method.

Eventually, CMS will remove claims-based reporting entirely, as stated in this year’s Final Rule: "to streamline the PQRS reporting options, as well as to encourage reporting options where eligible professionals are found to be more successful in reporting, it is our intention to eliminate the claims-based reporting mechanism in future rulemaking.”

While it’s still allowing claims-based reporting for 2015, CMS recommends that eligible professionals “use alternative reporting methods to become familiar with reporting mechanisms other than the claims-based reporting mechanism."


Well, 1,185 pages later, you’ve got the gist of it. Now that you’re stuffed full of information, you’ll need to make sure you and your clinic are ready for these changes. Still have questions? Register for our special PQRS webinar on November 25. And if you’re interested in WebPT’s PQRS solution, please email us at membervalue@webpt.com or call us at 866-221-1870, option 5, if you’re a Member. Not a WebPT Member yet? Contact us at sales@webpt.com or 866-221-1870, option 1.

Cashing In on Private Pay: The PT's Guide to Going Out-of-Network - Regular BannerCashing In on Private Pay: The PT's Guide to Going Out-of-Network - Small Banner
  • articleNov 4, 2013 | 3 min. read

    What PQRS Could Look Like in 2014

    On July 19, 2013, the Centers for Medicare & Medicaid Services (CMS) published the 2014 Medicare Physician Fee Schedule (MPFS) Notice of Proposed Rulemaking (NPRM) in the Federal Register. According to this summary , most of the policies were open for comment until September 6, 2013 and, pending final decisions (which hopefully will occur this month), will take effect on January 1, 2014. The 605-page document contains proposals for policy changes on everything from reimbursements to the …

  • articleNov 5, 2013 | 3 min. read

    Founder Letter: PQRS 2014

    Well, it’s November already, and that means two things: Thanksgiving and Physician Quality Reporting System (PQRS). Sure, PQRS doesn’t involve mouthwatering roasted turkey, savory stuffing, or creamy mashed potatoes, but it has become quite the November tradition for us here at WebPT. You see, this is the time of year that the Centers for Medicare & Medicaid Services (CMS) typically confirms the details of next year’s reporting requirements, thus allowing us to update our PQRS solution (claims- …

  • Founder Letter: Dodging Data will be Your Demise (or, Why You Should Complete PQRS)  Image

    articleNov 5, 2015 | 6 min. read

    Founder Letter: Dodging Data will be Your Demise (or, Why You Should Complete PQRS)

    By and large, Medicare’s 2016 Final Rule was underwhelming—and for most of us (including me), that probably warranted a big sigh of relief. But while there are no major changes on deck for this year, one thing that definitely should have caught your eye if you perused our Quick Guide to the 2016 Final Rule was the verbiage alluding to the future of PQRS—specifically, the possibility that PQRS reporting as we know it could cease to exist …

  • articleDec 26, 2013 | 5 min. read

    Most Frequently Asked Questions from our PQRS Webinar

    Once I pick my measures within WebPT, am I stuck with those throughout the year or can I change them? Yes, whichever measures you select will be your measures for the remainder of the year. You have until March 31, 2014, to make your final selection.   Is the requirement for successful reporting with the back pain measures group 20 patients per therapist or 20 patients per practice? It’s 20 patients per therapist. It doesn’t matter if …

  • The Scoop on PQRS Image

    articleNov 18, 2013 | 5 min. read

    The Scoop on PQRS

    What is PQRS? The Centers for Medicare and Medicaid Services (CMS) developed Physician Quality Reporting System (PQRS), which mandates that eligible professionals meet standards for satisfactory reporting. If you are not PQRS-compliant in 2014, CMS will assess penalties. However, we do not yet know what the penalty amount is or how CMS will assess it. There also is a chance that CMS will provide incentive payments for successfully completing PQRS, as they did in 2013. Again, we …

  • webinarDec 20, 2013

    Preparing for PQRS 2014

    In December, we hosted a webinar focused on the new PQRS regulations. This session broke down all the rules for 2014 to ensure you’ll be prepared to play by them and therefore not incur any penalties. During this presentation, we: Detailed the PQRS requirements for 2014 Described the different reporting methods Explained how you can ensure you successfully report

  • articleNov 7, 2013 | 2 min. read

    FLR and PQRS: How Are They Different?

    Functional limitation reporting (FLR) and PQRS both fall under the ever-widening umbrella of Medicare regulations, and they both involve outcome measures and data codes. Still, they are completely separate requirements, each with its own set of rules. Confusing, we know. To help you sort out the differences, we’ve put together a short breakdown of each one as well as a detailed compare/contrast chart: The Basics of FLR On July 1, 2013, Centers for Medicare & Medicaid Services …

  • PQRS 2016 FAQ Image

    articleDec 10, 2015 | 17 min. read

    PQRS 2016 FAQ

    Yesterday, we hosted a webinar focused on PQRS 2016. We received a lot of questions during the live session—so many, in fact, that we’ve amassed them here in a handy FAQ. Got a question and don’t see an answer below? Ask it in the comment section at the bottom of this post. Eligibility Do I have to participate in PQRS? What makes me an eligible provider? If you are a healthcare professional providing services paid under or …

  • Final Rule 2015: Here’s What You Need to Know Image

    articleNov 6, 2014 | 3 min. read

    Final Rule 2015: Here’s What You Need to Know

    The summary of this year’s Final Rule is hot off the presses, which means that—among other things—we now know the details regarding PQRS 2015. For those who have been following the PQRS saga since the program first came into being in 2007, it should come as no surprise that Medicare has yet again upped the ante for compliance. Based on the fact sheet CMS provided , here’s the scoop on this year’s reporting requirements: Eligible professionals who …

Achieve greatness in practice with the ultimate EMR for PTs, OTs, and SLPs.