Frequently asked questions about the Physician Quality Reporting System — January 2015

Topics include who oversees the PQRS program, what qualifies as a “group” practice and CMS penalties for unsuccessful reporting.
Who oversees the PQRS reporting program? Is it the same Medicare Administrative Contractor who handles the Medicare claims in my area?

PQRS is not run by the Medicare Administrative Contractors. The CMS Office of Clinical Standards and Quality administers several quality improvement programs for the agency, including PQRS.

The measures all seem to be based on patients suffering from major depressive disorder (MDD), but my practice focuses on helping patients with anxiety disorders. Does this mean I can’t participate in PQRS?

While it is true that several of the measures involve patients with MDD, other measures can be used with any diagnosis. For example, measures #130, documentation of current medications in the medical record, and #181, elder maltreatment screen and follow-up plan (for patients 65 and older), do not require specific diagnoses.

What constitutes a “group” for PQRS reporting? Could several psychologists with solo practices sign up as a group just for the purpose of reporting PQRS measures?

A group is defined as two or more providers who share a common tax identification number (TIN) and have reassigned their billing rights to that TIN. Psychologists cannot report under PQRS as a group without meeting these requirements.

If I am part of a group practice, do I still have the option of reporting individually?

If the practice has signed up to report under the group reporting option, you cannot choose to separately report PQRS measures as an individual because your National Provider Identification (NPI) number is linked to the TIN used by the group.

I received a letter from the Centers for Medicare and Medicaid Services (CMS) saying I will be penalized this year (2015) because I did not meet the PQRS requirements in 2013. Is there anything I can do about that now?

If you made no attempt to report any PQRS measures in 2013, there is nothing you can do now about the 1.5 percent penalty that CMS will attach to your payments in 2015. If, however, you did report on at least one measure in 2013 but are now being told that your participation was unsuccessful you have a limited opportunity to request a review. During the period from Jan. 1, 2015, through Feb. 28, 2015, you may request an informal review online.

The letter from CMS also talked about a reduction under something called the Value-Based Payment Modifier (VM). Will this affect my 2015 payments as well?

No, psychologists’ payments are not subject to the VM at this time. The VM is currently being applied only to payments for physicians. Nonphysicians, solo practitioners and small group practices will not be impacted by the VM until 2018. APAPO will educate psychologists about the VM as CMS releases more information about how it will be applied to non-physicians.