In last week’s Alert, we summarized the requirements for participating in Medicare’s Physician Quality Reporting System (PQRS) in 2013.  One of the major changes to the PQRS program—which we deferred until this week—is the implementation of the Value-Based Payment Modifier (VBM) for groups of 100 or more eligible professionals (EPs), consisting of physicians and CRNAs and others described in detail below.Groups of 100 or more EPs — Watch out for the Value-Based Payment ModifierThe Patient Protection and Affordable Care Act (ACA) requires that Medicare implement a Value-Based Payment Modifier (VBM) that would apply to Medicare fee-for-service payments beginning in 2015. The VBM is intended to pay physicians differentially based on the quality and cost of their care.While CMS must adhere to certain statutory requirements, such as using the modifier to promote shared responsibility and systems-based care, the ACA gives CMS considerable flexibility in terms of implementing the VBM. The 2013 Medicare...