On April 16, 2013, CMS made some significant clarifications regarding PQRS. CMS is clearly working to align the quality measures from different programs and to assist practices in avoiding penalties.

Since healthcare reform was introduced, quality has been an important—though ambiguous—element of the final destination of healthcare reform. Quality measures are built into Meaningful Use, a part of the Triple Aim of ACOs and baked in the rhetoric of healthcare reform. The call on April 16th provided increased clarity for physician practices. Currently they have reporting options that include submitting measures sourced from administrative claim data, Registry submission, EHR Systems, or GPRO web-based submission.

The developments in PQRS for 2013 definitely incentivize certain reporting options, penalize others, and allow some to phase out with no financial impact. In order to support practices with implementing PQRS, CMS has extended the self-nomination/registration opportunity for 2013 to include summer of 2013 until October 15th, 2013. In previous years, GPRO registration had to be received by January 31st. This registration extension makes GPRO (group reporting) a viable option for more practices. The practice size that can utilize GPRO now extends to two or more physicians, although web-based submission is only an option for groups of 25 or more eligible providers (EP). GPRO enables practices to participate in PQRS as a group to earn 2013 incentive payments (.5% of the group’s estimated 2013 Medicare Part B) as a lump sum to the TIN and to avoid the 2015 PQR payment adjustment (1.5% of the 2015 Medicare Part B payments which increases to 2% starting in 2016 and beyond).

If you have a group practice with 2-24 EPs, the Registry reporting process is satisfactory for reporting, receiving incentives, and avoiding penalties. The requirements at this level are pretty simple. Each eligible professional must satisfactorily report on at least 80 percent of eligible instances for at least three measures or report on a 20-paitent sample (if reporting measure groups) to qualify for the 2013 PQRS incentive payment. The Administrative Claim method can also be used. It will avoid the 2015 penalty, but will not qualify for PQRS Incentives and is largely a manual process. Qualified EHR systems will be able to submit 2013 PQRS data that will allow them to qualify for the incentives and avoid the penalty.

Groups with more than 25 EPs have some decisions to make. If they choose to use the Registry method, each EP will have to report individually and the requirements are more complicated. If the physicians groups with over 25 EPs choose to participate in web based GPRO they can report as a single group. Though it is a new process, automation is becoming more readily available, and struggling performers will have a smaller impact on the entire group when calculating performance for the group.

To make the best choice for your group practice, it is important to research these new developments and weigh the alternatives before deciding how to submit your physician quality reporting data.