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- One Year Out—What Do Anesthesiologists Need to Know About ICD-10-CM Conversion?
- One Year Out—What Do Anesthesiologists Need to Know About ICD-10-CM Conversion?
- Anesthesia Practices Prepare for the Health Insurance Exchanges
- Will the Medicare Physician Value-Based Payment Modifier Affect Your Anesthesia Group?
- Before the Shoe Drops: Anesthesiologists Can Help Hospitals Prevent Certain Hospital-Acquired Infections
- What Anesthesiologists Should Know About Third Party Payer Performance
- CERT Errors of Interest to Anesthesiologists and Pain Medicine Providers: Will the New A/B Contractor CERT Task Force Make a Difference?
- Will Medicare Publish Information on Payments to Anesthesiologists and Other Physicians?
- Legislative Replacement for SGR is on the Horizon for Anesthesiologists and other Physicians
- Drug Manufacturers' Payments to Anesthesiologists are Now Reportable Under the Sunshine Act
- Revisiting Readmissions as a Quality Metric for Hospitals and Anesthesiologists
- Will the Health Insurance Exchanges Mean More Patients for Anesthesiologists?
- New PQRS Reporting Requirements in the Proposed 2014 Medicare Fee Schedule Rule—Limited Impact on Anesthesia
- Looking at Bundled Payments from an Anesthesiology Perspective
- Preventable Hospital Readmissions—Opportunities for Anesthesiologists
- Do the Payers Understand Nerve Blocks for Post-Anesthesia Pain?
- Lessons from Bundled Payment Initiatives for Anesthesiologists
- Anesthesia Group Communications and the Attorney-Client Privilege
- Update on the SGR for Anesthesiologists and Pain Physicians
- Is Your Hospital Ripe for a Merger or Acquisition? What Anesthesiologists Need to Know Now
- When is an Anesthesiologist “Immediately Available?”
- Anesthesiologist Compensation
- Insights for Anesthesiologists: Participating in Hospitals’ New Strategies
- Anesthesiologists and Pain Physicians: Make Sure You are Enrolled in PECOS Now
- Hospitals May Pay for Anesthesia and Pain Medicine EHRs without Violating the Self-Referral or Anti-Kickback Laws
- Proposed “Medical Necessity” Restrictions on Post-Anesthesia Pain Blocks
- PQRS, the Value-Based Payment Modifier and Large Anesthesia Groups
- PQRS Refresher for Anesthesiologists, CRNAs and Pain Physicians
- ACOs, Antitrust and Anesthesiologists
- New Ways for Anesthesiologists to Add Value to the Management of their O.R.s
- Do ACOs Matter to Anesthesiologists and Pain Physicians Yet?
- How Safe Are Anesthesia Practices From a RAC Attack?
- The Sun Shines on Payments from Drug Companies to Anesthesiologists and other Physicians
- What Anesthesiologists and Pain Physicians Should Know about Health Insurance Exchanges
- The Company Model Presents Risks for Anesthesiologists and for ASCs
- Update Your Anesthesia Compliance Program: The Final HIPAA Privacy, Security and Breach Notification Rules Are Here
- Medicare Locality Conversion Factors for Anesthesia Services Through 2013
- 2013 CPT Coding Changes Pain Management and Anesthesia
- What Anesthesiologists Should Know About Health Insurance Exchanges
- Rental Networks, Claims Repricers and Anesthesia Practices
- Anesthesia Managed Care Contract Rates
- Giving Thanks for Anesthesiologists
- The Fiscal Cliff and What it Means to Anesthesiologists
- Final Fee Schedule Rule for 2013 Cuts Conversion Factors, Allows Payment to Nurse Anesthetists for Chronic Pain Services
- Anesthesiologists and Payment for Acute Pain Services
- Sedation by Non-Anesthesia Providers
- The SGR and Anesthesiology — It’s That Time of Year Again
- Anesthesia Business Consultants to Aid Anesthesiologists in Securing the Benefits of Meaningful Use through Complete EHR with F1RSTUse
- Compensating Anesthesiologists for Attending Group Meetings
- The OIG Targets “Personally Performed” Anesthesiologist Services
- A Warning for Anesthesiologists and Pain Physicians about Increased Billings through Better Technology
- Value-Based Purchasing for Hospitals Starts Now—and for Anesthesiologists, in 2015
- Anesthesiologists’ Role in Helping Surgery Centers Meet Their Quality Reporting Requirements
- Protect the Privacy and Security of Your Anesthesia Patients’ Electronic HIPAA Information
- New Hardship Exception for Anesthesiologists to Avoid the EHR Penalty
- Effective Hospital-Anesthesia Group Contracting: Understanding the Relationships Between Finance, Operations and Compliance
- When Negotiations with Carriers Force Anesthesiologists to Go Out of Network
- Anesthesiologists’ Investments in ASCs
- Proposed Changes for Anesthesiologists and Pain Physicians Who Report Measures to the PQRS
- Payment and Quality Changes Affecting Anesthesiologists in the 2013 Proposed Fee Schedule Rule
- What Anesthesia Practices Should Do With Unclaimed Funds Belonging to Patients
- After the Supreme Court Decision: Anesthesiologists Must Proceed With a Perioperative Care Model
- What Does Medicare’s 3-Day Payment Rule Mean for Anesthesia and Pain Practices?
- Tips for Anesthesia Practices to Get the Surgeons to the OR on Time
- OIG to Anesthesia Practices: Think Again Before You Pay Your ASC for the “Franchise”
- Latest Government Fraud Reports and How They Affect Anesthesiologists and Pain Physicians
- As an Anesthesiologist, What Should I Do About Meaningful Use if I am a Medicaid Provider?
- Collecting Payments from Anesthesia and Pain Medicine Patients
- Anesthesiology Plays a Role in Coordinating Management of Knee Replacement Patients, Contributing to Better Outcomes
- What the Proposed 60-Day Overpayment Refund Rule Means for Anesthesia Practices
- A New Quality Tool for Anesthesia Departments
- Managing Compensation for Anesthesiologists, CRNAs and AAs
- Medicare ACOs Are Blooming (With or Without Anesthesiologists)
- The Affordable Care Act, the Supreme Court and Anesthesiologists – Just the Facts, Please
- ICD-10 Delay Will Benefit Anesthesia and Pain Medicine Practices
- Medicare Updates of Interest to Anesthesiologists and Pain Physicians
- Practice Management Companies’ Acquisitions of Anesthesia Practices
- What Anesthesiologists Should Know about Medicare Prepayment Reviews
- Performance Based Compensation: Benchmarking, Monitoring and Improving Quality
- Performance-Based Compensation in Contracts between Hospitals and Anesthesia Groups: Measures
- Demystifying “Meaningful Use” for Anesthesiologists
- The Anesthesia Conversion Factor and the Medicare Fee Schedule, 20 Years Later
- Postoperative Pain Management Procedures Can Still Be Reported Separately from the Anesthesia Service
- Hospital Value-Based Purchasing Program: An Introduction for Anesthesiologists
- 2011 Medicare Rates for Anesthesia and Other Services Extended Through February
- Texas Statute Requires Anesthesia Informed Consent
- Results of Survey Regarding a Network of Anesthesia Practices
- PQRS 2012 for Anesthesiologists and Pain Specialists
- Anesthesia and the Version 5010 Standard
- How Will the Affordable Care Act Affect Anesthesiologists After the Supreme Court Rules?
- Information Technology, Patient Safety and Anesthesia Practice
- Be Careful With What You Say About One Another
- Do the Finalized ACO Regulations Help Anesthesiologists?
- A Major Change to the Perioperative/Anesthesia IT Integration Landscape
- 1 Anesthesia Group + 1 Anesthesia Group > 2 Anesthesia Groups
- Federal Budget Proposals and Medicare Payments for Anesthesia Services
- E-Prescribing by Anesthesiologists and Pain Physicians: Web Portal to Request Exemption is Up and Running
- HIPAA Privacy Rule Update for Anesthesiologists
- Electronic Prescribing: Anesthesiologists Will Soon Be Able to Request Their Exemptions
- The Medicare Bundled Payment Iniative and Anesthesia Services
- Anesthesia Providers: Plan to Revalidate Your Medicare Enrollment When Your Carrier Asks
- Medicare’s eRx and EHR Incentive Programs – Clearing Up the Confusion for Anesthesiologists
- Anesthesia and Social Media
- A Manual for all Anesthesiologists
- The IPAB Threat to Anesthesiologists and All Other Physicians
- Anesthesiology and the Proposed Rule for the 2012 Medicare Fee Schedule
- When is an Anesthesiologist's Signature Good Enough for Medicare?
- Health Plans Tighten the Belt – Around Anesthesiologists’ and Others’ Midsections
- Information from ASA on (1) Joint Commission Requirements and (2) Anesthesia Information Management
- Most Anesthesiologists Will Be Exempt from Medicare Electronic Prescribing Penalties ">
- Anesthesiologists' and CRNAs' Error Rates in Reporting PQRS Measures
- More Facet Joint Injection Pain
- Developing Leaders in Anesthesiology
- Anesthesiologists Visit Congress
- Compliance Update for Anesthesiologists
- Anesthesiologist and CRNA Participation Rates in the Physician Quality Reporting Initiative (PQRS), and New Compensation Data
- Preparing Your Anesthesia Practice for the 5010 Eletronic Transactions Standard
- ACO Proposed Rules–Will the Potential Waivers from Medicare Fraud Laws Benefit Anesthesiologists?
- Anesthesia Practice Cost and Revenue Data
- The Future As Seen From the Anesthesia Administration Assembly Conference
- What Should Anesthesiologists Know About the RACs?
PQRS REFRESHER FOR ANESTHESIOLOGISTS, CRNAs AND PAIN PHYSICIANS
March 25, 2013
Participating in Medicare’s Physician Quality Reporting System (PQRS) has taken on a new flavor this year. While until now participating has meant a potential annual bonus of several thousand dollars, not reporting in 2013 will entail a penalty in 2015. Losing out on a bonus is less galling than forfeiting a percentage of each remittance. No anesthesiologist, CRNA or pain physician is doomed to lose money for failing to report the applicable PQRS measure(s). This Alert will provide a reminder of the steps you need to take to earn the bonus and to avoid future penalties.
It is a testament to the undue complexity of the program that we are now in its seventh year, and yet uncertainty lingers. As a reminder, the incentive payments and “payment adjustments” for each year are as follows:
|Reporting Year||Payment or (Adjustment)|
|2016 onward||2014 onward||(2.0%)|
Transition from a Positive to a Negative Payment:
If you successfully report in 2013, early in 2014 you will receive a bonus payment equal to 0.5% of your 2013 Medicare allowables. If, however, you do not successfully report the requisite PQRS measures this year, not only will you give up the 0.5% bonus, but two years later, in 2015, your remittances will be reduced by 1.5%—i.e., you will be paid 98.5% of the Medicare Fee Schedule amount that would otherwise apply. Similarly, failure to meet the minimum reporting requirements in 2014 will result in payments of just 98% of the Medicare amount in 2016.
Earning the Incentive Payment for 2013:
As in previous years, the most familiar way for anesthesiologists, pain physicians and CRNAs to report the PQRS quality measures is via claims-based individual measures. The “eligible professional” (EP) simply includes the appropriate 5-digit Quality Data Code (QDC) on the claim submitted to Medicare. The EP must:
- Report at least three PQRS measures; OR
- If fewer than three measures apply to the eligible professional, report 1-2 measures; AND
- Report each measure for at least 50% of the eligible professional's Medicare Part B FFS patients seen during the reporting year to which the measure applies.
The three measures applicable to surgical anesthesia are once again:
- Measure #30 Perioperative Care: Timely Administration of Prophylactic Parenteral Antibiotics
- Measure #193 Perioperative Temperature Management
- Measure #76 Prevention of Catheter-Related Bloodstream Infections
Pain physicians who do not perform any surgical anesthesia cases can choose from a number of PQRS measures that can be reported with evaluation and management (E&M) services, including the following:
- Measure #130 – Documentation of current medications in the medical record
- Measure #131 – Pain Assessment and follow-up using a standardized tool to measure pain level and follow-up plan.
- Measure #128 – Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-up (if the patient is eligible and outside normal BMI limits, must document follow-up plan)
- Measure #226 – Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention
Detailed instructions for reporting all of the measures are available in the 2013 Measure Specifications available on the PQRS website, http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/.
The specifications for Measures #30, #76, #193, #130, #131, #128 and #226 can be downloaded from the ABC Website, www.anesthesiallc.com.
One? Two? Or Three Measures?
According to CMS, EPs “who choose to report 2013 PQRS individual measures should select at least three clinically applicable measures to submit in an attempt to qualify for a PQRS incentive payment. If fewer than three measures are reported via claims, CMS will apply a measure-applicability validation (MAV) process when determining incentive eligibility. For those eligible professionals who satisfactorily submit QDCs for fewer than three PQRS measures, a measure-applicability validation (MAV) process will determine whether they should have submitted QDCs for additional measures.”
Physicians and CRNAs, therefore, can qualify for the PQRS bonus without reporting on all three measures, although the safest course is to attempt to report no fewer than three measures. If an EP reports fewer than three measures, CMS will use the Measure Applicability Validation (MAV) test to determine whether there are other measures that the EP should have reported. The MAV is a two-part test. First CMS will examine whether other services were clinically related and therefore potentially applicable. “Clinical relation,” for these purposes, has been defined in a set of measure “clusters.” Second, CMS will apply a minimum threshold test to see whether another measure in the cluster was applicable to the EP’s practice because s/he had reported it at least once. If the EP reports any measure 15 or more times throughout 2013, it will apply, and he or she will need to report the measure in at least 50% of eligible Medicare cases in order to earn the incentive payment.
There are still just two anesthesia clusters:
|• Cluster 31||Anesthesia Care 1||Measure #30 and Measure #76|
|• Cluster 32||Anesthesia Care 2||Measure #76 and Measure #193|
(When reporting #76 alone, without any instances of Measure # 30 or Measure #193, it is not subject to MAV)
Because of the complexities of the MAV process and the possibility that an EP may lose an expected bonus through that process, we believe that the most conservative strategy is for every EP to report at least three measures. CMS will only apply the MAV test if the EP reports fewer than three measures. Why take the risk?
The most common method of reporting individual PQRS measures is through the use of a five-digit code (“Quality Data Code” or QDC) placed on the claim. Anesthesiologists may alternatively report through a qualified registry (such as the Anesthesia Quality Institute’s National Anesthesia Clinical Outcomes Registry or NACOR). To earn the incentive through registry reporting, EPs must report at least three measures, and report each measure for at least 80 percent of the EP’s Medicare patients seen during the reporting period to which the measure applies. A third option involves reporting through an electronic health record (EHR), which we will discuss in a later Alert if reader interest warrants.
PQRS also provides for reporting defined measures groups instead of the individual measures discussed in this Alert. Measures groups are of marginal relevance to our readers and we will likewise defer that topic to a later discussion.
Avoiding the Payment Penalty in 2015
The good news is that EPs can avoid the 2015 payment adjustment by reporting “at least” one valid measure via claims, registry, or qualified EHR. Qualifying for the bonus by satisfactorily reporting the applicable number of measures in 2013 will also exempt the EP from the penalty. As noted above, in the interest of maximum simplicity and income protection, anesthesiologists, pain physicians and CRNAs may want to identify and report on no fewer than three measures.
A third method of avoiding the penalty will involve affirmatively electing to participate in CMS’ new PQRS administrative claims reporting mechanism by October 15, 2013. CMS will make available details on how to choose this option later in the year.
Groups of 100 or more EPs – Watch out for the Value-Based Payment Modifier (VBM)
Last but not least, new rules impose a new mandate on groups of 100 or more EPs. Those large groups must sign up in 2013 for one of the three PQRS group reporting options&mdash even if their members choose to participate in PQRS at the individual level—in order to avoid a potential 1% payment penalty under the VPM in 2015. Group practices with 100 or more physicians that do not participate in PQRS in 2013 will automatically receive a VBM of −1.0% in 2015, according to CMS. That pay cut would come on top of the 1.5% reduction for not successfully reporting quality data in PQRS in 2013.
We will leave a full discussion of the VBM for next week’s Alert. The PQRS is sufficiently complex for now. ABC will work with all of our clients to help you qualify for the PQRS incentive payments, as long as those remain available, and avoid any PQRS or VBM penalties. We will also continue to publish information on this complex and dynamic subject.
With best wishes,
President and CEO