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.