Are you on track with PQRS?
As Medicare’s Physician Quality Reporting System (PQRS) continues to evolve, psychologists who participate in Medicare need to be aware of the program’s changing requirements if they wish to avoid financial penalties in future years. This year marks the end of the PQRS bonus payments; the program is shifting to penalizing providers who do not participate successfully.
The 2014 reporting data will determine if a provider incurs a 2 percent penalty on all of his or her Medicare charges in 2016.
The Centers for Medicare and Medicaid Services (CMS) expects eligible professionals participating in PQRS to report on a larger number of measures this year. Those looking to receive the 0.5 percent bonus for 2014 must report on at least nine measures for 50 percent of their applicable Medicare cases, a significant increase from the three measures required in previous years. Also new for 2014, the nine measures must fall into three out of six categories (referred to as “domains”) identified by the National Quality Strategy (NQS). The NQS domains represent federal priorities in the effort to improve health and the quality of health care:
- Patient safety.
- Person- and caregiver-centered experience and outcomes.
- Communication and care coordination.
- Effective clinical care.
- Community/population health.
- Efficiency and cost reduction.
The measures most applicable to psychologists are in the following domains:
||Effective clinical care
|No. 130: Documentation of medication||No. 9: Antidepressant medication management||No. 128: Preventive Screening: BMI|
|No. 181: Elder maltreatment screen and follow-up plan||No. 106: Adult MDD: comprehensive depression evaluation||No. 131: Pain assessment and follow-up|
|No. 107: Adult MDD: suicide risk||No. 134: Preventive Care: depression screening|
|No. 247: Substance Use Disorders: Counseling||No. 173: Preventive Care: unhealthy alcohol use|
|No. 248: Substance Use Disorders: Screening for Depression|
|No. 325: Adult MDD: Coordination of care of patients with specific comorbid conditions|
To avoid the penalty in 2016 all providers, including those new to PQRS, must report on at least three measures but do not have to spread the three measures across different domains.
While the increase in the minimum number of measures may seem daunting, it is critical to understand that CMS anticipates that specialties providing a limited number of services will have fewer applicable measures to choose from than multi-faceted primary care practices. Psychologists who report on fewer than nine measures or nine or more measures across fewer than three domains will not automatically fail. Instead, their reports will undergo a second-stage review known as the Measure Validation Process (MAV).
The MAV process
The MAV process will be used for two purposes in 2014: to determine eligibility for receiving the 0.5 percent incentive payment for 2014 and for avoiding the 2.0 percent payment penalty in 2016.
If a psychologist reports between three and eight measures across fewer than three domains, the MAV process will be employed. The MAV process will examine whether the measures reported are part of a clinically related “cluster,” meaning a group of measures applicable to a particular health problem.
Only the cluster on depression contains several measures likely to be used by psychologists. The depression cluster (#11) includes the following measures:
- No. 9 — Major Depressive Disorder (MDD): Antidepressant Medication During Acute Phase for Patients with MDD
- No. 106 — Major Depressive Disorder (MDD): Diagnostic Evaluation
- No. 107 — Major Depressive Disorder (MDD): Suicide Risk Assessment
- No. 130 — Description of Current Medications in the Medical Record
- No. 134 — Preventive Care and Screening: Screening for Clinical Depression and Follow-Up Plan
- No. 226 — Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention
If the psychologist reports measures that are not part of the depression cluster, or if they are part of the cluster but the MAV determines that other measures in this cluster could not have been used, then the psychologist will be considered eligible for the incentive payment and will avoid the 2016 payment adjustment.
A psychologist who reports on fewer than three measures will go through the MAV process, but only for the purpose of avoiding the 2016 payment adjustment. If the one or two measure(s) reported are not part of the depression cluster then the psychologist will not be subject to the 2.0 percent penalty in 2016. If they are part of the cluster, consideration of whether other cluster measures could have been reported will determine if the psychologist incurs the penalty.
A registry is an electronic system created by a vendor that allows eligible professionals to enter quality measurement information for PQRS. CMS maintains a list of registries qualified to submit PQRS data on its website. A list of qualified registries for 2014 (PDF, 503KB) appears on the CMS website.
Although not used as often as claims-based reporting by mental health professionals, registries are an important option for psychologists to explore following the decision by CMS to make some measures ineligible for claims-based reporting in 2014.
Two individual measures previously reported by psychologists through claims, No. 9 (Antidepressant Medication Management) and No. 173 (Unhealthy Alcohol Use Screening) now must be reported through a registry or electronic health records. In addition, all measures groups, including the dementia measures group, must now be reported via a registry. Measure No. 325, Adult Major Depressive Disorder, Coordination of Care of Patients with Specific Comorbid Conditions, has always been limited to registry reporting.
For 2014 registry and claims-based reporting have the same requirements: nine measures across three domains for 50 percent of the eligible professional’s applicable Medicare cases.
Use of a registry can save time as measures and G codes no longer need to be added to claims. The data may be submitted as late as February of the following year. Registries automatically update the list of PQRS measures annually. Costs vary but psychologists should expect to pay at least $250 to $300 annually to report through a registry. It is important to verify that a registry can support all the measures on which a psychologist might report.