DEPARTMENTS: PRACTICE POINTS
The Physician Quality Reporting System (PQRS) is in full documentation swing for the calendar year 2016. An eligible provider (EP) must report quality measures to avoid penalties in the future, as discussed in the September column of Practice Points. If he/she is not satisfying PQRS reporting, the EP will be subject to a reduction in pay, called the PQRS Negative Payment Adjustment.1 To assist you in understanding the PQRS program, the Centers for Medicare & Medicaid Services (CMS) has set up a “Frequently Asked Questions” section for PQRS: https://questions.cms.gov/faq.php?id=5005&rtopic=2141. Below are a few excerpts from the questions and answers provided on the PQRS CMS website.
- FAQ #11948: May I report or submit PQRS Measure #127: Diabetes Mellitus: Diabetic Foot and Ankle Care, Ulcer Prevention–Evaluation of Footwear as a non-MD/DO clinician who performs the quality actions described numerator?
CMS Reply: Yes. Measure #127 may be reported by non-MD/DO clinicians who perform the quality actions described in the measure based on the services provided and the measure-specific denominator coding via the registry reporting mechanism. The numerator of the measure explains the clinician performing the quality action should conduct a foot examination documenting the vascular, neurological, dermatological, and structural/biomechanical findings. The foot should be measured using a standard measuring device, and counseling on appropriate footwear should be based on risk categorization. Clinicians reporting this measure should be working within their scope of practice and be able to perform the quality action required.
- FAQ #12260: For the PQRS program, how is Measure #110, (National Quality Forum 0041): Preventive Care and Screening: Influenza Immunization reported for patients seen in the flu season (October 1 through March 31), even if the flu immunization was administered by another provider?
CMS Reply: There are 2 quality actions that will meet performance for Measure #110 Preventive Care and Screening: Influenza Immunization. The first quality action is actual administration of the vaccine. The other quality action is documentation that the immunization had been delivered during the current immunization season. Therefore, if the EP documents the immunization was administered by another provider, the quality action for the numerator has been met. For PQRS program years 2015 and 2016, the influenza immunization should be reported once for visits during January 1 through March 31 and reported once for visits October 1 through December 31 (of the current reporting period) for the prior year flu season and current year flu season. For example, if a patient is seen in February and received his/her flu shot in November of the prior year, the EP would report G8482. If the same patient returns in October, within the same reporting period, and receives a flu shot for the current season, the EP would again report G8482.
If it is determined that a patient received the influenza immunization by another provider (August 1 through March 31), it is appropriate to report G8482. In circumstances where the patient has been given an order to receive the flu shot for the current season or the vaccination was not available, the EP should report G8483: Influenza Immunization Not Administered for Documented Reasons.
- FAQ #10058: What is Measure-Applicability Validation?
CMS Reply: Measure-Applicability Validation (MAV) is a validation process that will determine whether individual EPs or group practices should have reported additional measures or additional domains. The MAV determines 2014 PQRS incentive eligibility and 2016 PQRS payment adjustment status for individual EPs and group practices. In the instance an individual EP or group practice has satisfactorily reported 9 or more measures across 3 or more domains, MAV would not apply, and the individual EP or group practice could earn the 2014 PQRS incentive and avoid the 2016 PQRS payment adjustment.
The MAV is applied to individual EPs and group practices that report less than 9 measures or less than 3 domains for PQRS. If MAV analytically determines that the EP or group practice could have reported additional measures or domains within the clinical cluster, then the 2014 PQRS incentive would not be earned, and the 2016 PQRS payment adjustment may apply. Claims-based MAV is applicable to individual EPs, whereas registry-based MAV is applicable to individual EPs and group practices.
The claims- and registry-based MAV materials contain more information about this topic and can be found for the specific PQRS program year on the PQRS website on the Analysis and Payment page: www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/AnalysisAndPayment.html.
Be sure to remember these 4 important points as you continue your PQRS reporting: engage in the process, determine your patient population, and know your services provided in your workplace, choose and understand how your measure selection supports your patient population and services provided, and map your documentation to your PQRS workflow and review your PQRS report often.