June 28, 2010
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Medicare Payment Update – 2.2% Increase Approved On Friday, June 25th, the President signed into law the bill that postpones the 21.3% SGR cut for another six months, the Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010 (H.R. 3962). The legislation also provides for an increase of 2.2 percent. Payments will drop back on December 1st if Congress fails to take further action on the SGR. CMS promptly issued a notice explaining how it will process claims for June through November: This law establishes a 2.2 percent update to the Medicare Physician Fee Schedule (MPFS) payment rates retroactive from June 1 through November 30, 2010. The Centers for Medicare & Medicaid Services (CMS) has directed Medicare claims administration contractors to discontinue processing claims at the negative update rates and to temporarily hold all claims for services rendered June 1, 2010, and later, until the new 2.2 percent update rates are tested and loaded into the Medicare contractors’ claims processing systems. Effective testing of the new 2.2 percent update will ensure that claims are correctly paid at the new rates. We expect to begin processing claims at the new rates no later than July 1, 2010. Claims for services rendered prior to June 1, 2010, will continue to be processed and paid as usual. Both the increase and the postponement are only in effect through November 30, 2010. All interested parties need to continue urging their Senators and Representatives to eliminate the SGR formula once and for all. Late-Breaking News on the 2011 Medicare Rate: A Further Reduction of 6.1% Congressional action is all the more urgent because of the proposed 2011 fee schedule rule that CMS released on June 25th: payments to physicians would be cut another 6.1 percent. Watch for additional information. |
If you have not begun reporting Physician Quality Reporting Initiative (PQRI) measures on your claims to Medicare, you will have a second and final opportunity starting this Thursday, July 1. You can qualify for the 2% bonus incentive payment on your Medicare allowables for the six-month period July-December by reporting quality measures on at least 80% of your eligible claims.
Recall that the PQRI requires physicians to report on at least three measures, unless only one or two measures apply to their particular practices. The three measures available to anesthesiologists are:
- #30, Perioperative Care: Timely Administration of Prophylactic Parenteral Antibiotics
- #76, Prevention of Catheter-Related Bloodstream Infections (CRBSI): Central Venous Catheter (CVC) Insertion Protocol
- #193, Perioperative Temperature Management
As explained in our January 11, 2010 Alert, it is not necessary to report on all three measures. It will suffice to report:
- Measure #30 and Measure #76, or
- Measure #193 and Measure #76, or
- Measure # 76 alone.
Since the 2% PQRI incentive will turn into a penalty for practitioners who do not successfully report on the applicable minimum of quality measures beginning in 2014, under the Patient Protection and Affordable Care Act (PPACA), anesthesiologists who have not yet integrated PQRI reporting into their practices should consider taking this opportunity. Participating in the second half of 2010 will be the last chance to earn 2 percent. The bonus will start to decrease in 2011 and become a 2% payment reduction for physicians who do not report PQRI measures in 2016:
- 2011 incentive payment: 1%
- 2012-14 incentive payment: .5%
- 2015: 1.5% reduction
- 2016 and later: 2% reduction
Do the PQRI or SCIP Measures Really Improve the Quality of Care? The JAMA Article
In an important article published in the June 23-30 issue of JAMA, Adherence to Surgical Care Improvement Project Measures and the Association with Postoperative Infections, JAMA. 2010;303(24):2479-2485, Stulberg et al. analyzed discharge data from Premier Inc’s Perspective Database, representing approximately 20% of U.S. hospital discharges, and concluded that there was no clinically meaningful association between reported compliance with the SCIP infection control measures and decreases in postoperative infection rates.
The SCIP measures are sometimes confused or at least mis-identified with the PQRI measures. In fact, the six SCIP infection-control measures are the progenitors of the corresponding PQRI measures, but the latter were validated through numerous additional means, not least of which were multi-stakeholder consensus groups. Thus there are such differences as the applicability of the PQRI normothermia measure, #193, to many more procedures than the colorectal surgery specified in SCIP INF-7. See the table of SCIP postoperative infection prevention measures below.
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Individual SCIP Measures
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Although the JAMA study failed to demonstrate any improvement in infection rates attributable to adherence to the individual SCIP measures, it did suggest that aggregate adherence had a positive effect:
Our results are consistent with previous findings regarding public report of process-of-care quality data. Based on our findings, the individual item performance rates reported publicly do not fulfill their stated purpose of pointing consumers toward high-quality hospitals. However, when taken in aggregate, improved performance on our global all-or-none composite measure is associated with improved outcomes at the discharge level. Therefore, while the individual items may not imply quality differences, the overall ability to demonstrate adherence to multiple SCIP processes of care may.
We have often heard – and written – that the PQRI is a set of “training wheels” for quality-based payment. To date, only three measures (or fewer) need to be reported in order for a provider to be eligible for the PQRI bonus, at least using the individual claims method of reporting. The requisite combination of measures depends not on clinical outcomes but on clinical relatedness. The JAMA article may help hasten the transition from today’s PQRI process-of-care reporting to an outcomes-based system that will earn the respect of the anesthesiology community.
With best wishes,
Tony Mira
President and CEO