2011 Physician Quality Reporting System
The Center for Medicare and Medicaid (CMS) issued the 2011 Medicare Physician Fee Schedule Final Rule on November 29, 2010. The Final Rule made several changes to the Physician Quality Reporting System incentive program for 2011. The most visible change to the program is lowering of the reporting threshold to 50 percent from 80 percent, if reporting via the claims process. Registry reporting still requires reporting each measure 80 percent of the time on individual measures, due to registry reporting having a 90-percent success rate. The change in the claims process will improve PQRS success. The name of the program has been updated to the Physician Quality Reporting System (PQRS); the program had previously been called the Physician Quality Reporting Initiative (PQRI). To participate in the program, professionals may report individual PQRS quality measures or group measures through one of these methods: To CMS on their Medicare Part B claims (claims-based reporting) To a qualified Physician Quality Reporting registry (registry-based reporting) Professionals who satisfy the reporting criteria will earn a Physician Quality Reporting incentive payment equal to 1 percent of their total Medicare Part B Physician Fee Schedule (PFS) charges, excluding drugs and biologics. The Affordable Care Act authorizes incentive payments through 2014. Physician Quality Reporting Incentive Payment through 2014 2011 1% 2012 0.5% 2013 0.5% 2014 0.5% Beginning in 2015, the Affordable Care Act authorizes a penalty for eligible professionals who do not satisfactorily report quality measures. Eligible professionals who do not meet the reporting criteria in 2015 will be subject to a 1.5 percent reduction in their fees. The penalty for unsatisfactory reporting rises to 2 percent from 2016 onward. The PQRS does not require eligible professionals to register to participate in the program. A list of eligible professionals can be found on the CMS website at http://www.cms.gov/PQRI/Downloads/EligibleProfessionals.pdf. Physician Quality Reporting System Quality Measures The 2011 Physician Quality Reporting System includes 194 individual quality measures, an increase from the 179 quality measures used in 2010. There are seven otolaryngology specific measures. It is important that you review all of the measures to select those most frequently applied to your Medicare patients. You should also review them to make sure none of the measure specifications have changed if reporting on the same measures from 2010. It is also important to note that certain measures can only be reported using a CMS-approved registry. The measures listed below apply directly to otolaryngology, although there are non-specialty specific measures that may apply to your practice. MEASURES 91 Acute Otitis Externa (AOE): Topical Therapy 92 Acute Otitis Externa (AOE): Pain Assessment 93 Acute Otitis Externa (AOE): Systemic Antimicrobial Therapy – Avoidance of Inappropriate Use 94 Otitis Media with Effusion (OME): Diagnostic Evaluation – Assessment of Tympanic Membrane Mobility 188 Referral for Otologic Evaluation for Patients with Congenital or Traumatic Deformity of the Ear 189 Referral for Otologic Evaluation for Patients with History of Active Drainage from the Ear within the Previous 90 Days 190 Referral for Otologic Evaluation for Patients with a History of Sudden or Rapidly Progressive Hearing Loss CMS has also established measure groups that pertain to a particular condition or have a common area of focus. Group measures have different specifications than the individual measures that make up the group. Currently, only the perioperative care measures group may be applicable to otolaryngologists. The perioperative care measures group includes the following measures: MEASURES GROUP 20 Perioperative Care: Timing of Antibiotic Prophylaxis – Ordering Physician 21 Perioperative Care: Selection of Prophylactic Antibiotic – First OR Second Generation Cephalosporin 22 Perioperative Care: Discontinuation of Prophylactic Antibiotics (Non-Cardiac Procedures) 23 Perioperative Care: Venous Thromboembolism (VTE) Prophylaxis (When Indicated in ALL Patients) You can review the individual and group measures and their specifications on the CMS website. The 2011 Physician Quality Reporting System (Physician Quality Reporting) Measures List can be viewed at https://www.cms.gov/PQRI/15_MeasuresCodes.asp. Satisfactorily Reporting Quality Measures The 2011 incentive program has established criteria for satisfactorily reporting quality measures based on the reporting mechanism and the reporting period. The table below outlines the reporting criteria and reporting periods. TABLE 1. REPORTING CRITERIA AND PERIODS Reporting Mechanism & Period PQRS Measures Patient Threshold Claims-based Reporting – 12-month period January 1, 2011 – December 31, 2011 Report 3 or more PQRS measures (Eligible professionals may report 1-2 measures if less than 3 apply to their practice) =50% of Medicare Part B FFS patients seen during the reporting period Claims-based Reporting – 6-month period July 1, 2011 – – December 31, 2011 Report 3 or more PQRS measures (Eligible professionals may report 1-2 measures if less than 3 apply to their practice) =50% of Medicare Part B FFS patients seen during the reporting period Registry-based Reporting – 12-month period January 1, 2011 – December 31, 2011 Report 3 or more PQRS measures (measures with a 0% performance rate will not be counted) =80% of Medicare Part B FFS patients seen during the reporting period Registry-based Reporting – 6-month period July 1, 2011 – – December 31, 2011 Report 3 or more PQRS measures (measures with a 0% performance rate will not be counted) =80% of Medicare Part B FFS patients seen during the reporting period As the table highlights, eligible professionals, in most cases, are required to report at a minimum three quality measures within the selected reporting period in addition to meeting the patient threshold criteria. TABLE 2. GPRO II REPORTING REQUIREMENTS Group Size (Number of Eligible Professionals) Number of Measures Groups Required To Be Reported Minimum Number of Patients in Each Measures Group Number of Required Individual Measures To Report Percent of Medicare Part B Patients in Denominator for Satisfactory Reporting Individual Measures Via Claims Percent of Medicare Part B Patients in Denominator for Satisfactory Reporting Individual Measures Via Registries Required Number of Unique Visits Where an Electronic Prescription Was Generated to Be a Successful Electronic Prescriber 2–10 1 35 3 50% 80% 75 11-25 1 50 3 50% 80% 225 26-50 2 50 4 50% 80% 475 51-100 3 60 5 50% 80% 925 101-199 4 100 6 50% 80% 1875 Group Practice Reporting CMS has expanded the group practice reporting option under the 2011 PQRS incentive program. A self-nomination is required for group practices to participate in both GPRO I and GPRO II. Due to the requirements of GPRO I, it is not applicable to otolaryngologists. GPRO II expanded group reporting to include groups with 2 – 199 members. Table 2 identifies the reporting requirements for GPRO II based on group size. At a minimum, GPRO II requires group practices to report on one measures group and three individual measures. (Individual measures may not be in the measures group report.) Further information on the group practice reporting option can be found on the CMS website: https://www.cms.gov/PQRI/22_Group_Practice_Reporting_Option.asp. Maintenance of Certification Program Incentive In 2011, physicians who satisfactorily meet the reporting requirements of the PQRS for a 12-month period, either as an individual or as a member of a group practice, may qualify for an additional 0.5 percent maintenance of certification incentive payment. Each individual specialty board must apply to CMS to obtain approval for a MOC program to meet this incentive. Next steps Here is a list of recommendations to assist you in participating in the 2011 PQRS incentive program. Review the measures list for the 2011 PQRS incentive program; several new quality measures have been introduced while others have been retired. Having determined the measures that are applicable to your practice, review each measures specification. Determine which mechanism you will use to report measures. Clarify the reporting period you will participate in, 12-month (Jan. 1-Dec. 31) or 6-month (July 1-Dec. 31).
The Center for Medicare and Medicaid (CMS) issued the 2011 Medicare Physician Fee Schedule Final Rule on November 29, 2010. The Final Rule made several changes to the Physician Quality Reporting System incentive program for 2011. The most visible change to the program is lowering of the reporting threshold to 50 percent from 80 percent, if reporting via the claims process. Registry reporting still requires reporting each measure 80 percent of the time on individual measures, due to registry reporting having a 90-percent success rate. The change in the claims process will improve PQRS success. The name of the program has been updated to the Physician Quality Reporting System (PQRS); the program had previously been called the Physician Quality Reporting Initiative (PQRI).
To participate in the program, professionals may report individual PQRS quality measures or group measures through one of these methods:
- To CMS on their Medicare Part B claims (claims-based reporting)
- To a qualified Physician Quality Reporting registry (registry-based reporting)
Professionals who satisfy the reporting criteria will earn a Physician Quality Reporting incentive payment equal to 1 percent of their total Medicare Part B Physician Fee Schedule (PFS) charges, excluding drugs and biologics. The Affordable Care Act authorizes incentive payments through 2014.
Physician Quality Reporting
Incentive Payment through 2014
2011 | 1% |
2012 | 0.5% |
2013 | 0.5% |
2014 | 0.5% |
Beginning in 2015, the Affordable Care Act authorizes a penalty for eligible professionals who do not satisfactorily report quality measures. Eligible professionals who do not meet the reporting criteria in 2015 will be subject to a 1.5 percent reduction in their fees. The penalty for unsatisfactory reporting rises to 2 percent from 2016 onward.
The PQRS does not require eligible professionals to register to participate in the program. A list of eligible professionals can be found on the CMS website at http://www.cms.gov/PQRI/Downloads/EligibleProfessionals.pdf.
Physician Quality Reporting System Quality Measures
The 2011 Physician Quality Reporting System includes 194 individual quality measures, an increase from the 179 quality measures used in 2010. There are seven otolaryngology specific measures. It is important that you review all of the measures to select those most frequently applied to your Medicare patients. You should also review them to make sure none of the measure specifications have changed if reporting on the same measures from 2010. It is also important to note that certain measures can only be reported using a CMS-approved registry.
The measures listed below apply directly to otolaryngology, although there are non-specialty specific measures that may apply to your practice.
MEASURES | |
91 | Acute Otitis Externa (AOE): Topical Therapy |
92 | Acute Otitis Externa (AOE): Pain Assessment |
93 | Acute Otitis Externa (AOE): Systemic Antimicrobial Therapy – Avoidance of Inappropriate Use |
94 | Otitis Media with Effusion (OME): Diagnostic Evaluation – Assessment of Tympanic Membrane Mobility |
188 | Referral for Otologic Evaluation for Patients with Congenital or Traumatic Deformity of the Ear |
189 | Referral for Otologic Evaluation for Patients with History of Active Drainage from the Ear within the Previous 90 Days |
190 | Referral for Otologic Evaluation for Patients with a History of Sudden or Rapidly Progressive Hearing Loss |
CMS has also established measure groups that pertain to a particular condition or have a common area of focus. Group measures have different specifications than the individual measures that make up the group. Currently, only the perioperative care measures group may be applicable to otolaryngologists.
The perioperative care measures group includes the following measures:
MEASURES GROUP | |
20 | Perioperative Care: Timing of Antibiotic Prophylaxis – Ordering Physician |
21 | Perioperative Care: Selection of Prophylactic Antibiotic – First OR Second Generation Cephalosporin |
22 | Perioperative Care: Discontinuation of Prophylactic Antibiotics (Non-Cardiac Procedures) |
23 | Perioperative Care: Venous Thromboembolism (VTE) Prophylaxis (When Indicated in ALL Patients) |
You can review the individual and group measures and their specifications on the CMS website. The 2011 Physician Quality Reporting System (Physician Quality Reporting) Measures List can be viewed at https://www.cms.gov/PQRI/15_MeasuresCodes.asp.
Satisfactorily Reporting Quality Measures
The 2011 incentive program has established criteria for satisfactorily reporting quality measures based on the reporting mechanism and the reporting period. The table below outlines the reporting criteria and reporting periods.
TABLE 1. REPORTING CRITERIA AND PERIODS | ||
Reporting Mechanism & Period | PQRS Measures | Patient Threshold |
Claims-based Reporting – 12-month period January 1, 2011 – December 31, 2011 |
Report 3 or more PQRS measures (Eligible professionals may report 1-2 measures if less than 3 apply to their practice) | =50% of Medicare Part B FFS patients seen during the reporting period |
Claims-based Reporting – 6-month period July 1, 2011 – – December 31, 2011 |
Report 3 or more PQRS measures (Eligible professionals may report 1-2 measures if less than 3 apply to their practice) | =50% of Medicare Part B FFS patients seen during the reporting period |
Registry-based Reporting – 12-month period January 1, 2011 – December 31, 2011 |
Report 3 or more PQRS measures (measures with a 0% performance rate will not be counted) | =80% of Medicare Part B FFS patients seen during the reporting period |
Registry-based Reporting – 6-month period July 1, 2011 – – December 31, 2011 |
Report 3 or more PQRS measures (measures with a 0% performance rate will not be counted) | =80% of Medicare Part B FFS patients seen during the reporting period |
As the table highlights, eligible professionals, in most cases, are required to report at a minimum three quality measures within the selected reporting period in addition to meeting the patient threshold criteria.
TABLE 2. GPRO II REPORTING REQUIREMENTS | ||||||
Group Size (Number of Eligible Professionals) | Number of Measures Groups Required To Be Reported | Minimum Number of Patients in Each Measures Group | Number of Required Individual Measures To Report | Percent of Medicare Part B Patients in Denominator for Satisfactory Reporting Individual Measures Via Claims | Percent of Medicare Part B Patients in Denominator for Satisfactory Reporting Individual Measures Via Registries | Required Number of Unique Visits Where an Electronic Prescription Was Generated to Be a Successful Electronic Prescriber |
2–10 | 1 | 35 | 3 | 50% | 80% | 75 |
11-25 | 1 | 50 | 3 | 50% | 80% | 225 |
26-50 | 2 | 50 | 4 | 50% | 80% | 475 |
51-100 | 3 | 60 | 5 | 50% | 80% | 925 |
101-199 | 4 | 100 | 6 | 50% | 80% | 1875 |
Group Practice Reporting
CMS has expanded the group practice reporting option under the 2011 PQRS incentive program. A self-nomination is required for group practices to participate in both GPRO I and GPRO II. Due to the requirements of GPRO I, it is not applicable to otolaryngologists.
GPRO II expanded group reporting to include groups with 2 – 199 members. Table 2 identifies the reporting requirements for GPRO II based on group size. At a minimum, GPRO II requires group practices to report on one measures group and three individual measures. (Individual measures may not be in the measures group report.)
Further information on the group practice reporting option can be found on the CMS website: https://www.cms.gov/PQRI/22_Group_Practice_Reporting_Option.asp.
Maintenance of Certification Program Incentive
In 2011, physicians who satisfactorily meet the reporting requirements of the PQRS for a 12-month period, either as an individual or as a member of a group practice, may qualify for an additional 0.5 percent maintenance of certification incentive payment. Each individual specialty board must apply to CMS to obtain approval for a MOC program to meet this incentive.
Next steps
Here is a list of recommendations to assist you in participating in the 2011 PQRS incentive program.
- Review the measures list for the 2011 PQRS incentive program; several new quality measures have been introduced while others have been retired.
- Having determined the measures that are applicable to your practice, review each measures specification.
- Determine which mechanism you will use to report measures.
- Clarify the reporting period you will participate in, 12-month (Jan. 1-Dec. 31) or 6-month (July 1-Dec. 31).