Does PQRS apply to you? If you’re a physical therapist providing services paid under—or based on—the Medicare Physician Fee Schedule, you’re subject to PQRS regulations. However, these regulations aren’t static; they change from year to year. So, if you haven’t brushed up on the latest CMS Final Rule, you might not be aware of some key details on what’s in store for PQRS 2016. But, don’t worry. You won’t have to comb through every dense page of legislation, because I’ve already done that for you. Here’s what you need to know to satisfy PQRS requirements—and avoid the associated penalties—in 2016:
Although PQRS reporting isn’t “mandatory,” if an eligible provider chooses not to participate in 2016—or if the provider fails to satisfy the reporting requirements—then Medicare will assess a 2% penalty on his or her 2018 fee schedule. No bueno. In order to satisfactorily report, you must:
- Report on nine measures across three different NQS domains.
- For PTs, there are only six measures available for claims-based reporting and eight for registry-based reporting. This means PTs automatically undergo the Measure Applicability Validation (MAV) process—more on that later.
- Report on at least one cross-cutting measure.
- Submit data for at least 50% of your Medicare Part B patients.
That’s a lot of data to track. And once you’ve accurately documented the necessary information, how do you submit it to Medicare? There are a few options:
Registry-Based Reporting (Automatic Individual Submission)
This option allows you to submit all your PQRS data through a registry. And speaking of registries, WebPT is a Certified PQRS Registry—so with us, all you have to do is report your PQRS measures directly within the patient record as you go through your typical documentation workflow. Then, we then aggregate that data, compile it digitally, and submit it to CMS on your behalf. So, after setup, you document, and we take care of the rest. Essentially, registry-based reporting means you’ll never forget PQRS because we remember all of the nitty-gritty details for you.
Claims-Based Reporting (Manual Individual Submission)
With this method, you record quality codes for each eligible patient on the corresponding claim form. Then, the responsibility falls on your shoulders to submit these codes properly on your Medicare claims.
Group Practice Reporting Option (GPRO) (Automatic Group Submission)
This option is available only for multi-therapist practices (i.e., those with two or more therapists). When you select this option, you have to report on PQRS measures as a group through a shared tax ID. And before you begin reporting, you must sign up for GPRO on the GPRO website. Refer to CMS for more information about GPRO.
The MAV Process
No matter which reporting method you choose, if the number of measures that apply to you is below the number you’re required to report, you will be subject to the MAV process. So, for 2016, all PTs are subject to this process. Although the MAV process might sound intimidating, it’s really not that scary. Medicare simply uses it to determine whether you should’ve reported on additional measures.
In accordance with its goal to obtain quality data, Medicare will not count any measures that have a 0% performance rate. For every eligible patient, you must denote that the PQRS measure was:
- Met (e.g., a quality action was performed);
- Not Met (e.g., a quality action was not performed); or
- Excluded, which means that there is a documented reason for not meeting the performance criteria. Keep in mind that not all measures allow for exclusions.
If you mark “Not Met” or “Excluded” for a patient who is eligible for a particular measure, then you will have a 0% performance rate for that measure. Sometimes, you’re justified in skipping the measure or excluding the patient—and your documentation should justify that decision. However, if you simply exclude the patient as a way to avoid actually completing the measure, that means you aren’t taking a quality action. With that in mind, you should be able to complete PQRS measures for most of your eligible patients. And when you don’t, you score a 0% performance rate for the measures you skip—which means Medicare won’t count those measures toward the 50% minimum reporting requirement. I can’t stress this enough: it’s crucial that we, as PTs, start caring about data initiatives, take the time to complete quality actions, and submit accurate data.
PQRS is complex, but the right EMR system makes the process super simple. With WebPT’s PQRS solution, you get built-in safeguards that remind you what—and when—to report. Plus, you gain access to reports that display your PQRS progress, so you’ll always know exactly how many patients you’ve seen, which data you’ve reported, and how far you’ve progressed toward meeting the minimum requirements for reporting. Plus, if you choose our registry option, you don’t even have to worry about submitting all of your information. We take care of that for you, too. Sure beats trying to manually track and submit all of that data.
Sure, it takes a little extra time and effort, but submitting accurate PQRS data—or any data for that matter—is crucial. And with the right EMR in place, you can take the headaches out of the equation. For more information on everything PTs, OTs, and SLPs need to know about PQRS 2016, check out my latest webinar.