Psychologists may have been unfairly penalized based on 2014 Physician Quality Reporting System data

The APA Practice Organization identified discrepancies in the application of an internal review process used to evaluate psychologists’ reporting data, and contacted the Centers for Medicare & Medicaid Services to resolve the issue.

Psychologists who participated in the Physician Quality Reporting System (PQRS) for 2014 may have been unfairly penalized or denied an incentive in 2016. The Practice Organization contacted the Centers for Medicare & Medicaid Services (CMS) after learning that a psychologist in California did not qualify for the 2014 incentive because she was unable to find nine measures that fit her practice.

The psychologist reported eight measures, scoring a perfect performance rate on each measure. An informal review of her case resulted in a second denial, indicating that she could have reported a measure on blood pressure screening. The psychologist did not conduct or feel qualified to conduct blood pressure screenings.

PQRS currently requires eligible professionals (EPs) to report on nine measures across three quality domains. If an EP does not or cannot meet the reporting requirement, CMS applies the Measure Application Validation (MAV), an internal process designed to determine if there were other measures that could be reported, and potentially shield EPs from the 2 percent penalty. For 2014, an EP could seek a 0.5 percent incentive payment in 2016 by reporting on nine measures, or alternatively avoid a 2 percent penalty in 2016 by reporting only three measures.

On a recent telephone call, CMS agreed with the Practice Organization that not all psychologists should be expected to report the blood pressure screening measure simply because the measure contains CPT® codes used by psychologists. The agency determined that the psychologist should have received an incentive payment under the MAV process and will issue the payment later this year.

CMS asked the Practice Organization to help collect information from psychologists who feel their data may not have been accurately reviewed under the MAV process.

If you believe you were incorrectly penalized or denied an incentive payment, email a copy of your individual performance reports (also known as a feedback report) to the Practice Organization. The most common errors involve feedback reports suggesting psychologists should have reported measures that are not applicable to their practice and/or do not contain CPT codes that psychologists use for billing.

Those with questions about how to access their performance reports should contact the QualityNet Help Desk by telephone at (866) 288-8912 or by email.

While CMS will take steps to avoid future faulty evaluations under MAV, the agency stressed that psychologists who believe they may have been unfairly penalized for their 2015 reporting should file a request for an informal review.

Having been alerted to some of the challenges psychologists face in PQRS, CMS will be better prepared to analyze future requests for review of psychologists’ reporting data. Letters indicating if a penalty will be applied in 2017 based on the 2015 reporting data are expected to be mailed in the fall.