November 10, 2014

CMS released the Final Rule on the Physician Fee Schedule containing next year’s Physician Quality Reporting System (PQRS) requirements on October 31, 2014.  As expected, Measure #30, Timing of Antibiotic Prophylaxis-Administering Physician, has been deleted from the list of measures available for either claims-based or registry reporting.  So has the Back Pain Measures Group (Measures #148-151) and Measure #142, Assessment for Use of Anti-Inflammatory or Analgesic Over-the-Counter (OTC) Medications, but CMS did not ultimately remove Measure #109, Osteoarthritis:  Function and Pain Assessment, from the list.

For 2015, the following are the basic PQRS measures applicable to anesthesiology:

And the following is a sample of PQRS measures that may be applicable to your pain medicine practice:

Please note that neither of these lists necessarily represents the complete universe of measures that you may be able to report.  There may be others that also apply to your practice, and there may be measures groups that you would choose to report.  Also, several measures have been deleted in the 2015 rule, e.g., Measure #148, Assessment for Use of Anti-Inflammatory or Analgesic Over-the-Counter (OTC) Medications, and Measure #248, Screening for Depression among Patients with Substance Abuse or Dependence.  You should plan to select the measures that you will be reporting as more detailed information becomes available so as to meet at least the minimum requirements for 2015.

How Many Measures Must You Report?

If one measure is all that applies to your practice, that is still all that you have to report in 2015 in order to avoid the two-percent penalty in 2017.  For a measure to count, you must report it in at least 50 percent of your eligible cases.

In general, CMS will require that eligible professionals (EPs) report on a minimum of nine measures representing at least three different National Quality Strategy (NQS) domains.  As the Agency states in numerous places throughout the Final Rule, however,

In the case that an eligible professional may not have at least 9 measures applicable to an eligible professional’s practice, the eligible professional may still be able to meet the satisfactory reporting criterion via claims and/or registry for the 2017 PQRS payment adjustment if the eligible professional reports on 1–8 measures.  The eligible professional would be required to report as many measures as are applicable to the eligible professional’s practice.  If reporting less than 9 measures covering 3 NQS domains, the eligible professional would be subject to the MAV process, which would allow us to determine whether an eligible professional should have reported quality data codes for additional measures.

The Measure Applicability Validation [MAV] process involves a two-part test, we reminded readers in our Alert of October 27 (“Preparing Your Anesthesia Practice for PQRS Reporting in 2015”).  In the first phase, CMS will apply the clinical relation/domain test to determine whether closely-related measures in a predefined “cluster” could also have been submitted.  In the second phase, the minimum-threshold test, CMS will determine whether the EP submitted at least 15 claims on which the measures could have been reported.  If not, then the closely related measures would not have been required in order to avoid the penalty.  In other words, during the January 1 through December 31 reporting period, if an EP treats more than a certain “threshold” number of Medicare patients with a condition to which a certain measure applies, then that EP should be accountable for submitting the quality data codes for that measure.  For further information on the MAV, CMS has indicated that the 2015 process will be very similar to 2014, which is described at http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/AnalysisAndPayment.html.  Updated documents are still in preparation at CMS headquarters.

At Least One of Your Measures Must Be a “Cross-Cutting” Measure – New Requirement in 2015

In the Proposed Rule, CMS introduced the idea of “cross-cutting” measures in order to “help bring alignment with respect to a set of measures all eligible professionals may report,” to “help in collecting data that are more varied to better capture the overall quality of care provided to patients” and to “create a core set of measures for PQRS.”  If the EP has seen at least one Medicare patient in a face-to-face encounter during 2015, the EP must report on at least one of the 19 measures contained in the list of cross-cutting measures (Table 52 on page 78 in the Final Rule).

Six of the measures identified in the tables above as being applicable to either anesthesiology or pain medicine are “cross-cutting.”  Every EP in an anesthesia or pain practice should make sure to report, for at least 50 percent of the patients seen in a face-to-face encounter, at least one of the following PQRS measures (and as many of the other measures in Table 52 as may apply to the EP’s practice):

Until now, it has not been necessary for anesthesiologists to report on any of these “cross-cutting” measures in order to avoid the PQRS penalty.  Because of this change, the records given to billers and coders may need to be updated so that the new measures can be captured on the EP’s Medicare claims.

The total number of measures required to be reported is still nine—or one to eight, if that is all that applies to the EP’s practice.  If an EP sees at least one Medicare patient in a face-to-face encounter during the 12-month PQRS payment adjustment reporting period, i.e., 2015, at least one of the nine measures the eligible professional reports must be contained in the cross-cutting measure set.  Moreover, CMS states, “In the instance where an eligible professional may not have at least 9 measures applicable to his/her practice, the eligible professional would still be required to report at least 1 cross-cutting measure, if applicable.”  The MAV process will allow CMS to determine whether a group practice should have reported on any of the 19 crosscutting measures.

CMS promises to provide the specific codes for “what we define as a ‘face-to-face’ encounter and any additional guidance on the PQRS website at http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/index.html.  The Agency also asks that everyone note its “intention to move towards requiring the reporting of more cross-cutting measures in the future.”

A Word about the Qualified Clinical Data Registry (QCDR) Option

Like claims-based and registry methods, the QCDR option for PQRS participation requires EPs to report on nine measures across three different NQS domains.  Successful participation will require that an EP report on at least two outcome measures, or, or, in lieu of two outcome measures, at least one outcome measure and one of the following other types of measures:  resource use, patient experience of care, efficiency/appropriate use, or safety.  CMS had proposed a minimum of three outcome measures, as noted in our Alert of October 27th, but it reduced the number in the Final Rule.  Since the Anesthesia Quality Institute’s (AQI’s) National Anesthesia Clinical Outcomes Registry contains no fewer than six outcome measures, the lesser requirement is of no special benefit for anesthesiologists who choose the NACOR/QCDR option.

Anesthesia professionals who meet their PQRS requirements through the QCDR must report a minimum of nine measures—the MAV test does not apply here.  It should also be noted that QCDR participation means reporting on at least 50 percent of all the EP’s patients, not just Medicare beneficiaries.

The Final Rule increased the number of non-PQRS measures that a QCDR may offer from 20 to 30 for 2015, as proposed.  It also extended by one month the deadline for QCDRs to submit quality measures data, including calculations and results, to March 31 following the end of the applicable reporting period (for example, March 31, 2016, for reporting periods ending in 2015).

It seems as though reporting quality measures to CMS becomes more and more complicated every year.  We at ABC will continue to do our utmost to help our readers understand and satisfy the evolving requirements.

With best wishes,

Tony Mira
President and CEO

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