GPRO is your futureJune 13th, 2013 by
All of us are titillated or alarmed, depending on your point of view, by the degree that the NSA is tracking our electronic activities. Perhaps that story raised my awareness of how far-reaching the strategic thinking of our colleagues in government can be. Here is an apparent example.
My own naiveté about CMS’s strategies slapped me good this week when the Quality Net Help Desk answered a query about PQRS penalties.
We’d asked: How do the penalties work for physicians/extenders who fail to satisfy PQRS reporting requirements? (Providers who fail to meet the minimum requirement for reporting at least one PQRS measure during 2013 will have a 1.5% Medicare payment reduction in 2015). Do those penalties follow that provider if they change employment?
The answer from the Quality Net Help Desk was:
“If a provider does not meet the criteria to avoid the PQRS Payment Adjustment in 2013, they would receive the PQRS Payment Adjustment in 2015. The PQRS program is applied to the provider’s TIN/Individual NPI combination. So if a facility has multiple providers and some meet the requirements and some don’t, those who don’t meet the requirements would receive the payment adjustment, not all. If that provider leaves the facility, their TIN would more than likely be changing, therefore they would not receive the payment adjustment under their new TIN as that combination was not being measured in the timeframe to avoid the payment adjustment. “
As a practice administrator, that means that my tools for enforcing provider compliance with PQRS reporting are less effective. All of our providers work on some kind of productivity based model. The group’s income is governed by the payments we receive from Medicare Part B, our largest payment source. If we have provider staff who fail to successfully comply with the Medicare PQRS or eRx programs, our income suffers. Do we pass that loss on to the provider or suffer it at the practice level?
CMS is clearly imposing the penalties at the practice level and not on the provider since they can leave the practice with a clean slate. This is the same as a “get out of jail free” card for the provider. They can avoid penalties if they simply move on. For those of us who employ practitioners, that creates significant complications.
“Fortunately” CMS created a solution that moves PQRS reporting to the practice level – GPRO. GPRO (Group Practice Reporting Option) allows the entire group to satisfy PQRS reporting based on the active participation by a sub-set of providers. I previously posted a blog that praised the newly simplified GPRO for ePrescribing. Unfortunately, the PQRS GPRO is more cumbersome than the eRx one. Hopefully CMS will continue simplifying group reporting across the board.
Now, to tie GPRO back to my observations about a CMS strategy. The people who will suffer from the multiple CMS initiatives (PQRS, eRx, EHR and Value Based Purchasing) are small practices. Those are the providers who will have the most difficulty meeting these complex initiatives. Where will they go? I predict they will migrate to employee status with increasingly large medical practices or provider systems. Only large, well-funded groups, have the capacity to meet this ever-expanding array of challenges.
Is that coincidence or strategy? You be the judge.