Annual Review of 2015 PQRS reporting for LTPAC – Measure Groups and GPROFebruary 9th, 2015 by
This is the 2nd of two blog posts reviewing PQRS reporting options for LTPAC Medical Groups. All Physician groups are subject to a <2%> Medicare Part B payment reduction in 2017 if they fail to successfully report PQRS. Groups of 10 or more are subject to an additional <4%>1 VBP penalty for not reporting; those reporting poor quality scores may still suffer.
There are multiple ways to participate, including:
· reporting 9 individual measures,
· a measures group, or
· electing the GPRO (Group Practice Reporting Option.)
In a post dated Jan.06, 2015 we reviewed the Individual Measures strategies available for LTPAC groups. Today’s post covers the other options listed. There are additional PQRS reporting strategies which are rarely employed by LTPAC Medical groups and not discussed here.
PQRS Measure Groups that apply to LTPAC E&M + Psych Codes
Through 2014, Measure Group reporting was the 2nd most popular strategy. Submitting Individual Measures via Claims was in 1st place. Penalties were avoided by reporting a relatively low number of individual measures (3 or less), via Claims. Beginning in 2015 reporting by Individual Measures requires submission of 9 measures. More and more measures are only reportable via Registry. Even with a LTC oriented EHR, this is a very complex compliance burden. For a paper based practice, using claims submission for reporting individual measures is nearly impossible.
For 2015 we recommend all LTPAC Practices (actually all PCP groups) consider using Measures Groups. There are possible reasons to also track/report individual measures, but the 1st goal is avoiding penalties. Medical Practices considering use of a Measures group should review the definitions of the Measures in each group. Why? Look at the table above. There are two cells highlighted in light blue. Each shows a code family with missing CPT codes (e.g. Asthma only applies to 99341 – a level 1 homecare new patient visit). Similar illogical definitions permeate the PQRS, and eCQM, measures. Further, Measure definitions, particularly the denominator, can change between the individual and group versions.
If you use an EHR, never assume it works for LTPAC PQRS reporting. Most EHRs rely on eCQMs. Unless very thoughtfully designed, your group may not have 9 eCQMs that are ‘activated’ by LTPAC face to face encounters. Only a few EHRs feature PQRS Measures/Groups. (Shameless plug – our EHR, gEHRiMed®, was designed to help LTPAC medical groups satisfy PQRS as part of normal workflow).
The Measures group manual is available from CMS here.
Based on the available data, resources, and the patient population in LTPAC we continue with recommending certain LTPAC ‘friendly’ Measures Groups. LTC Physicians successfully report CAD, HF, and Dementia. None of those Groups’ measures prescribe clinical interventions that may be harmful to patients in LTPAC. HF used to require access to a LVEF report, a study often not available in LTC settings. That criteria was broadened to include documentation of Mild to Severe LVSD, a more reasonable standard. Both CAD and HF have dropped old, and added new, measures; each for a net gain of +2 measures. LTPAC Behavioral Health is still best served by resorting to the Dementia Measures group.
Measures Group Caveat: All Measures Groups are submitted by registry during January & February of the following year. Unless you have a very ‘smart’ EHR and/or PM system, you can submit successfully via a Registry and still FLUNK PQRS Reporting. CMS validates Registry Submissions against Claims Data – you must submit the qualifying Diagnosis Codes for any Registry Reported PQRS measures. This means your documentation scheme (EHR or Paper, etc.) has to convey the appropriate ICD-9 on the claim. There is no CMS ‘official’ documentation of this requirement, but it is confirmed by the QualityNet Help Desk.
Of all the options for PQRS and VBP reporting, GPRO is the most difficult to comprehend, much less explain. That’s because the definition keeps changing from year to year. The 2015 regulations are yet to be published; this blog uses 2014 as a reference point. What causes the confusion?
· The definition of a group keeps changing. The elements that change from year to year are size and composition (e.g. MD, NPP, mixed).
· Group Size determines reporting requirements. Small groups have options, large groups have requirements.
· Practices can ‘self-nominate’ for GPRO, but CMS will treat a practice as a group if >50% of its Eligible Professionals successfully report PQRS during the year.
· One of the reporting options, PQRS GPRO Measures Using the Web Interface Reporting Method, was required for large groups. The mandated measures are incompatible with the LTPAC population, including required Patient Surveys (CAHPS).
Unless your practice is highly sophisticated, your best bet is to select a traditional PQRS reporting strategy and monitor your Clinician’s performance. As long as >50% are reporting successfully, you will become a ‘group’ for both PQRS and VBP – but reporting individually gives added flexibility. A formal GPRO election may force your practice into a defect ridden strategy. Once CMS publishes the formal 2015 GPRO rules, we will reassess the available strategies and publish updates if needed.
Note 1: 2/6/2015 correction. Groups of >9 will receive a total penalty of <6%> for not reporting. Thanks to Carol Coates, Regulatory Director at ECP Management for alerting me.