October 26, 2009

Anesthesia practices that successfully participated in the Physician Quality Reporting Initiative (PQRI) in 2008 have begun receiving notices of payment from Medicare. Some practice administrators are wondering why the PQRI bonuses were lower than anticipated. Others are “pleasantly surprised” because they expected Medicare not to come through at all.

The practice-level reports that will allow groups to audit their PQRI payments will only be available several weeks from now, according to the notices. If your own notice did not contain any instructions on how to obtain access to your report once it is on line, you are not alone. The Centers for Medicare and Medicaid Services (CMS) has posted a number of Medicare Learning Network articles about obtaining the 2008 reports on its website, however, some of which we summarize below.

Obtaining PQRI Feedback Reports

It is not too early to begin the process of registering for access to your reports. Like last year – despite much criticism of the Fort Knox-style impenetrability -- they are stored on a website with multiple layers of security. One important change allows the individual physician to see the report on his or her own PQRI participation without going through the registration process. Beginning last Monday, October 19, individual “eligible providers” can call their respective carrier or A/B MAC Provider Contact Center to request 2007 Re-Run (available to a very few physicians) and 2008 PQRI feedback reports that will contain data based on their individual NPI. This means that anesthesiologists who are part of a group practice will be able to obtain their individual feedback reports as well. The reports should be e-mailed within 30 days of the request. If no report is available, the provider will receive an e-mail notification.

Group leaders, administrators and other delegates of the individual physician who has reassigned his or her benefits to the practice should follow these steps: designate a PQRI “Security Official” who will register the practice and approve the “users” who will have access to the PQRI Feedback Reports, i.e.,

Step 1. Register as an organization through the “Individuals Authorized to Access CMS Computer Systems” (IACS) system. (This applies even if you successfully registered with the IACS in 2008; you must renew your registration with the IACS every 60 days.)

1. One representative of the practice should go to https://applications.cms.hhs.gov and register as a “Security Official” via the “Account Management” tab. The Security Official’s job is to identify the group and to approve subsequent users who will be able to view the actual PQRI reports. He or she will enter the group’s “Legal Business Name” and Taxpayer Identification Number (TIN), i.e., Employer Identification Number.
2. The Security Official will then receive an e-mail from CMS’ End User Services Help Desk requesting IRS documentation containing IRS letterhead, the Legal Business Name and the TIN. Examples include IRS CP-575 forms, IRS 147C letters and Federal Tax Deposit Coupons.  
3. Within about ten business days and once the IACS registration information has been verified by the End User Services Help Desk, the Security Official will receive an IACS User ID and password in two separate e-mails.

Step 2. A second person should go to the same website, https://applications.cms.hhs.gov, and register as a User Group Administrator. The User Group Administrator will have access to the PQRI reports for the TIN, unlike the Security Official. Both the User Group Administrator and the Security Official will be able to approve End Users, if any. If only one representative of the practice will have access to the PQRI Feedback Report, s/he should still sign up to be the User Group Administrator.

1. The IACS will send an e-mail to the Security Official for approval.  
2. The User Group Administrator will receive an IACS User ID and password in two separate e-mails.  
3. Any additional users should go to the same Applications Portal on the website and register as end users in the organization User Group.  
4. The User Group Administrator will receive an e-mail from the IACS to approve the end user(s), who will receive their own two e-mails with an IACS user ID and a password.

Step 3. The User Group Administrator and/or end user will request a PQRI Feedback Report application role.

1. The Administrator and end users should once more go to https://applications.cms.hhs.gov, enter the Applications Portal and click on the tab for “Account Management.” This time the user should select “My Profile.”  
2. On the My Profile page, click the “Modify Account Profile” link.  
3. On the Modify Account Profile page under Access Request, select “Modify Provider Profile.”  
4. Select the “PQRI User” role.  
5. You will be presented the option to choose one of two PQRI roles: “PQRI approver” or “PQRI user”. In almost all cases “PQRI user” is the proper selection.  

Step 4. The User Group Administrator and/or end user(s) will go to http://www.qualitynet.org/pqri and enter their respective IACS User IDs and passwords to gain access to the group’s PQRI Feedback Report.

More information on registering as a Security Official, User Group Administrator or end user is available at:

http://www.cms.hhs.gov/MLNMattersArticles/downloads/SE0831.pdf and at:http://www.cms.hhs.gov/IACS/04_Provider_Community.asp#TopOfPage, where there is a Quick Reference Guide for each role.

You may also contact the End User Services Help Desk at 1-866-484-8049 Monday through Friday from 7:00 a.m. - 7:00 p.m. EST or by email: EUSsupport@cgi.com.

Making Sense of the PQRI Feedback Reports

For questions about PQRI feedback report availability and content, contact the QualityNet Help Desk Monday through Friday from 7:00 a.m. - 7:00 p.m. CST at 1-866-288-8912 or by email: qnetsupport@sdps.org. Questions that the QualityNet Help Desk should be able to answer include:

• Do I have a PQRI feedback report available for this TIN or NPI?
• When will my PQRI feedback reports be available?
• Why am I unable to view my PQRI feedback report on the PQRI Portal?
• Did I qualify for a PQRI incentive payment?
• When will my PQRI incentive payment be available?
• Can you explain a specific part of my PQRI feedback report?

That last question may become particularly important if the feedback reports for 2008 are as difficult to understand as the 2007 reports. CMS published, in September, a “User Guide to the 2007 Re-Run and 2008 Physician Quality Reporting Initiative (PQRI) Feedback Reports“ that looks highly informative and contains a set of screen shots of tables in the reports explaining which measures the group and the individual provider successfully reported, and which measures were not accepted. CMS is well aware that many providers felt that the 2007 feedback reports did not explain why they failed to qualify for an incentive payment. The new feedback reports will evidently analyze satisfactory reporting at the individual provider level and supply details on missing data, coding errors and NPI errors. Whether the report data bear any resemblance to the practice’s own records is of course the bottom line. CMS acknowledges the possibility of discrepancies and advises providers to contact their carriers or Medicare Administrative Contractors (MACs).

Conclusion

There are three overarching process problems that threaten the PQRI’s ability to change and improve the quality of medical care received by Medicare beneficiaries. The first is obtaining access to information on a group’s performance. CMS exempted individual physicians from the time-consuming burden of registering to receive their reports through the IACS, but merely attempted to explain the IACS better for everyone else. According to an American Medical Association survey of physicians who participated in the PQRI during 2007, more than six out of 10 physicians surveyed rated the program difficult, and only 22 percent were able to download the PQRI feedback report for their practice.

Second, the reports did not sufficiently enlighten physicians as to why they had not earned their incentive payments, as noted in CMS’ paper “Physician Quality Reporting Initiative (PQRI): 2007 Reporting Experiences“ The AMA survey revealed that of those who were able to access their feedback reports, less than half found the information instructive. Of the physicians who asked for assistance from CMS, 59 percent rated their satisfaction with CMS responsiveness as none to low.

Third, the feedback is too slow to affect performance. Anesthesiologists know that quality performance reports must be received while the clinical activity is still reasonably fresh in their minds. The oldest cases that determine eligibility for the 2008 bonus were performed 21 months ago and the corresponding PQRI reports will have little, if any, educational value.

The PQRI program is going to be with us for some time, though, and it is in the interest of every practice that participated in 2008 to try to find and understand CMS’ analysis of its success in reporting the PQRI measures. We hope that this Alert will help you in that endeavor.

With best wishes,

Tony Mira
President and CEO