April 27, 2015

The Anesthesia Quality Institute’s Qualified Data Clinical Registry (AQI QCDR) became even more valuable with the recent addition of 16 new measures bringing the total number of measures adopted by the AQI for use in its QCDR to 27.  With the nine official Medicare Physician Quality Reporting System (PQRS) measures that can also be reported to the QCDR, the combined total of 36 measures will give most anesthesiologists, nurse anesthetists and anesthesiologist assistants ample opportunity to satisfy the PQRS requirements for 2015.  The array of available measures should also provide practices with sound choices for their own quality measurement and improvement programs.

PQRS Reporting via the QCDR

Eligible professionals (EPs) must successfully participate in the PQRS in 2015 in order to avoid a two-percent negative payment adjustment in 2017.  Successful participation means reporting on a total of nine measures from three different National Quality Strategy (NQS) domains for at least 50 percent of the individual EP’s Medicare fee-for-service patients.  At least one of the measures must be from the list of 19 cross-cutting measures.  Unless anesthesiologists perform a lot of Evaluation and Management services, it will be impossible for them to find nine PQRS measures that apply to their practice.  They may avoid the penalty even though they report fewer than nine measures, but CMS will apply the measure applicability validation (MAV) test to determine whether more measures in fact did apply to their practices.  And EPs may not know whether they have successfully reported to PQRS until after the reporting year is over—when it is too late to correct any deficiencies

The QCDR makes PQRS reporting considerably simpler, more rational and more predictable.  The requirements for EPs who report as individuals (rather than as a group) are:

1. Report at least 9 measures covering 3 (NQS) domains for at least 50% of the EP’s applicable patients seen during the 2015 participation period. [QCDR measures are reported for all patients, while only Medicare patients are targeted by traditional claims-based PQRS reporting.]
2. Report on at least 2 outcome measures. If the QCDR does not possess 2 outcome measures, then the QCDR must possess at least 1 outcome measure and 1 of the following other type of measure: 1 resource use, OR patient experience of care, OR efficiency appropriate use, OR patient safety measure.

As noted at the outset, the AQI QCDR now offers a choice of 36 different measures, including outcome measures and multiple measures each covering the various NQS domains.  See Table 1 (QCDR Measures) and Table 2 (PQRS Measures) below for the titles of all 36 measures.  There will almost certainly be at least nine that apply to any anesthesia EP’s practice (it is likely, however, that a much smaller number will be available for pain medicine.  The AQI is planning to introduce more pain measures in the future.) The downside of CMS’ allowing QCDRs to use up to 30 of their own non-PQRS measures in 2015 is that the absolute minimum number that must be reported is nine.  EPs who report fewer measures will not be able to use the MAV test to validate the lack of availability of other appropriate measures.

Readers who scrutinize the two tables above will observe that there appears to be some duplication.  Specifically, both QCDR Measure #18 and PQRS Measure #193 are entitled “Perioperative Temperature Management.”  This highlights the need to look carefully at the measure specifications, detailed guides that spell out the clinical action (numerator), the eligible population (denominator), the CPT codes associated with the numerator and denominator, exclusions and the rationale for the measure.  For the PQRS Perioperative Temperature Management measure, #193, the PQRS Measures Codes Specifications Manual in the zip file 2015 PQRS Individual Claims Registry Measure Specification Supporting Documents identifies the “Percentage of patients, regardless of age, undergoing surgical or therapeutic procedures under general or neuraxial anesthesia of 60 minutes duration or longer, except patients undergoing cardiopulmonary bypass, for whom either active warming was used intraoperatively for the purpose of maintaining normothermia, OR at least one body temperature equal to or greater than 36 degrees Centigrade (or 96.8 degrees Fahrenheit) was recorded within the 30 minutes immediately before or the 15 minutes immediately after anesthesia end time.”  The newer QCDR measure, #18, however, lowers the acceptable threshold to 35.5 degrees but does not give, ask for or recognize documented efforts to maintain temperature in the OR.  The complete instructions for reporting #18 and the other 26 QCDR measures appear in AQI QCDR Measure Specification, Year 2015.  According to a Frequently Asked Question answered by the AQI, “The new temperature threshold is more consistent with the clinical literature” and “PQRS Measure 193 and ASA Measure 18 can both be reported for 2015.”

Quality Reporting via the QCDR

A group that wants to maintain its contracts with its hospitals, and in an increasing number of cases, with its payers, needs to measure the quality of care provided systematically.  The QCDR can help.  The 27 evidence-based measures developed by anesthesiologists for anesthesiology practice can potentially serve to raise the quality of patient care, not just to avoid Medicare penalties.  Tracking and improving scores across a broader range of valid quality metrics can yield competitive advantages.

Groups that want to get started with QCDR reporting need only contact the AQI (ABC clients should ask their account managers to begin the process).  The AQI is prepared to work with everyone to make sure that they have an appropriate method for submitting reports that will satisfy CMS requirements and the groups’ own needs.  During the month of May, the AQI will be holding “Virtual Office Hours” every Tuesday from 11:00-12:00 a.m. CDT.  Register and prepare the questions you will want to ask of AQI staff.

ABC strongly encourages you to take the opportunity to learn more about the AQI QCDR, which is, in our opinion, one of the most important services ever offered by the ASA.

With best wishes,

Tony Mira
President and CEO