Physician Quality Reporting System
The Physician Quality Reporting System (PQRS) (formerly known as the Physician Quality Reporting Initiative) started as a voluntary reporting program. The program provided an incentive payment to anesthesia practices with eligible professionals (identified on claims by their individual National Provider Identifier [NPI] and Tax Identification Number [TIN]) who satisfactorily report data on quality measures for covered Physician Fee Schedule (PFS) services furnished to Medicare Part B Fee-for-Service (FFS) beneficiaries (including Railroad Retirement Board and Medicare Secondary Payer).
The Physician Quality Reporting System is now mandated by federal legislation. CMS implements Physician Quality Reporting through regulations published in the Federal Register.
The traditional method of reporting quality data to CMS was accomplished by amending a modifier to the Medicare claim that reflected the provider’s compliance or noncompliance to a quality metric such as the timely administration of antibiotics prior to the procedure. In 2016, the list of measures that was available to Anesthesia has been reduced to a single measure which is:
PQRS #47 - Care Plan: Percentage of patients aged 65 years and older who have an advance care plan or surrogate decision maker documented in the medical record or documentation in the medical record that an advance care plan was discussed but the patient did not wish or was not able to name a surrogate decision maker or provide an advance care plan. (https://pqrs.cms.gov/dataset/2016-PQRS-Measure-047-11-17-2015/kt3r-29rt/data)
While this measure can be met by Anesthesia, it very often represents additional work and will not be a viable option in future reporting years. This is why CMS has made available two alternatives.
Qualified Registry Reporting
It can be confusing to differentiate between Qualified Registries and Qualified Clinical Data Registries, but the major difference is that Qualified Registries are restricted to report only PQRS measures while QCDRs have the option of creating their own specialty-specific quality measures. This has major implications to Anesthesia as there are a limited number of viable PQRS measures that conform to a group’s clinical practice.
Keeping with the requirement of reporting 9 measures to avoid all types of penalties and audits, Qualified Registry reporting is not a recommended method of conformance to the governmental requirement. One advantage of Qualified Registry reporting however is that it is only required on Medicare patients.
Qualified Clinical Data Registry (QCDR) Reporting
QCDR reporting offers the greatest level of flexibility and alignment with anesthesia practices and is the recommended approach for all providers (MDs, DOs, CRNAs). Participation and successful compliance with the measures, ensures providers are protected from payment adjustments outlined in the Merit-Based Incentive Payment System (MIPS) due to quality deficiencies.
QCDR reporting can be seen as a proactive reporting methodology rather than a reactive one such as claims-based PQRS reporting. While the methodology of QCDR Reporting is not governed by CMS, compliance with the various measures typically require a provider to actively document and/or measure an aspect of the clinical process or the patient’s outcomes. This information is then collected and aggregated to be submitted to CMS on the provider’s behalf.
One of the major differences between QCDR and claims-based PQRS is that QCDR reporting is required on all eligible patients and not just those covered by Medicare. This represents a substantive change in quality reporting from previous years and is one that should be incorporated into the current clinical process.
QCDR reporting looks to be the long-term approach regarding quality management that is supported by CMS and a growing number of commercial insurance carriers which is why ABC has recommended that all providers and groups support this initiative.