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PQRI Changes for Anesthesia Practices in the 2011 Medicare Fee Schedule

November 15, 2010

Last week’s Alert included the single most important item in the finalized CMS regulation (“Final Rule”) on the 2011 Medicare Fee Schedule: the 24.9 percent decrease in the respective conversion factors for anesthesia and for all other services. In this issue we will summarize changes regarding the Physician Quality Reporting Initiative (PQRI) incentive program.

The PQRI is going to have a new name – again. (It began in 2007 as the Physician Voluntary Reporting Program or PVRP.) Since CMS considers the program permanent, and no longer a “temporary initiative,” it will henceforth be the “Physician Quality Reporting System.” The abbreviation “PQRI” will continue to be in use, however, indefinitely, alongside “PQRS.”

The amount of the incentive payments will decrease in 2011 and eventually become negative, as we had expected.CMS will pay physicians who successfully report the applicable PQRI measures the following percentages of allowed Medicare charges:

  • 2011 1.0%
  • 012 0.5%
  • 2013 0.5%
  • 2014 0.5%
  • 2015 -1.5%
  • 2016 on -2.0%


Beginning in 2011, a 0.5% bonus will be available to physicians if they satisfactorily report data on PQRI measures through a maintenance of certification (MOC) program. Until CMS gives the MOC program run by the American Board of Anesthesiology official approval, though, anesthesiologists will not be eligible for the 0.5% bonus merely because they are maintaining their certification through their specialty board. If the ABA’s MOCA self-nominates by the deadline of January 31, 2011 and is approved, every anesthesiologist hoping to earn the bonus will need to do the requisite practice assessment in 2011. Even a diplomate whose board certification is not time-limited, or one who must be recertified or is first certified in 2010, will need to complete the practice assessment – and will also need to report the regular PQRS measures successfully over the full 12 months of the calendar 2011.For more information on the MOCA, please see the July 12, 2010 Alert. Note that CMS has clarified, in the Final Rule, that the MOC incentive is only available to physicians and “would not apply to other eligible professionals, such as CRNAs.”

Successful participation in Medicare’s PQRI program will be markedly easier in one important respect starting on January 1, 2011: physicians will only need to report PQRI “quality data codes” (QDCs) on 50 percent of their eligible claims instead of 80 percent to earn their incentive bonus. The objective is still to report 100 percent, but this has not always been possible, particularly in the case of anesthesiologists who practice in multiple facilities. As ASA noted in its formal comment letter responding to the proposed 2011 Fee Schedule regulation, “Some of these facilities handle the billing responsibilities for the anesthesiologist practice, but do not provide the opportunity for PQRI participation.” The new 50 percent threshold only applies to claims-based reporting.

CMS is adding 20 individual Physician Quality Reporting System measures (including new measures for reporting through registries and electronic health records) and one new measures group on which individual eligible professionals may report.(See Tables 80-82 on pages 1175-1180 of the Final Rule.) The Agency is also making 10 additional individual measures available for reporting through electronic health records systems, in addition to the 10 measures already available for electronic health record reporting. None of the new measures relate to the typical practice of anesthesiology.The three measures for anesthesiology are still:

The full list of measures should be released this week. For specific direction on how to report the 2011 measures, please consult the "2011 Physician Quality Reporting System Implementation Guide,” which CMS has promised to post by December 31, 2010, at http://www.cms.gov/pqri.

Reporting through a registry or using an electronic health record (EHR) are still not options for most anesthesiologists since there are as yet no registries or EHRs that qualify under the PQRI program. (Some EHRs may accept measures reported by pain specialists – not including Measures #114 [preventive care and screening: inquiry regarding tobacco use] and #115 [preventive care and screening: advising
smokers and tobacco users to quit], which have both been deleted and replaced by a new preventive care measure).

The Anesthesia Quality Institute is applying for recognition for the National Anesthesia Clinical Outcomes Registry (NACOR). In the Final Rule, CMS stated that it might not publish the list of eligible registries until the middle of the year after reviewing new requirements.

As required by the Patient Protection and Affordable Care Act (PPACA),CMS has undertaken to (1) provide timely feedback reports to eligible professionals about satisfactory reporting, including plans for interim feedback reports for claims-based reporting in future years; (2) create an informal review process for eligible professionals who wish to have CMS reexamine a determination that an eligible professional has not satisfactorily submitted data for the PQRS in the 2011 program year, and (3) establish the framework for a new “Physician Compare” website similar to www.hospitalcompare.hhs.gov.

Update on Incentive Payments for Participation in the 2009 PQRI Program

CMS has provided the following information regarding incentive payments for successful participation in the 2009 PQRI program:

Incentive payments for the 2009 Physician Quality Reporting Initiative (PQRI) are available this fall for eligible professionals who meet the criteria for successful reporting. Carriers and Medicare Administrative Contractors (MACs) will begin processing and distributing 2009 PQRI incentive payments on October 25, 2010. Distribution of 2009 PQRI incentive payments is scheduled to be completed by November 12, 2010.

Remember that PQRI incentives earned by individual participating physicians and other eligible professionals are paid as a lump-sum to the Taxpayer Identification Number (TIN) under which the professional’s claims were submitted. It is then up to the TIN to decide how to distribute the incentive within the practice.

Effective January 2010, CMS revised the manner in which incentive payment information is communicated to eligible professionals receiving electronic remittance advices. CMS has instructed Medicare contractors to use a new indicator of LE to indicate incentive payments instead of LS. LE will appear on the electronic remit. In an effort to further clarify the type of incentive payment issued (either PQRI or eRx incentive), CMS created a 4-digit code to indicate the type of incentive and reporting year. For the 2009 PQRI incentive payments, the 4-digit code is PQ09. This code will be displayed on the electronic remittance advice along with the LE indicator. For example, eligible professionals will see LE to indicate an incentive payment, along with PQ09 to identify that payment as the 2009 PQRI incentive payment. Additionally, the paper remittance advice will read, “This is a PQRI incentive payment.” The year will not be included in the paper remittance.

2009 PQRI feedback reports will be available on the Physician and Other Health Care Professionals Quality Reporting Portal starting the second week of November. TIN-level reports on the Portal require an Individuals Authorized Access to CMS Computer Services (IACS) account. Participants may also contact their Carrier/MAC to request individual NPI-level reports via an alternate feedback report fulfillment process; visit cms.gov for details.Watch for additional feedback report information from CMS.

Who to Contact for Questions?

If you have questions about the status of your PQRI incentive payment (during the distribution timeframe), please contact your Provider Contact Center. The Contact Center Directory is available on the CMS website.

Contact the QualityNet Help Desk with any of the following:
  • PQRI Portal password issues
  • PQRI/eRx feedback report availability and access
  • PQRI-IACS registration questions
  • PQRI-IACS login issues

The QualityNet Help Desk is available Monday through Friday from 7:00 a.m. – 7:00 p.m. CST at 1-866-288-8912 or via qnetsupport@sdps.org. They can also assist with program and measure-specific questions.

The above information supplements the Guide for Understanding 2009 eRx Incentive Payment previously published by CMS.

An Anesthesiologist and 20 Other Physicians in Congress

ABC warmly congratulates Andy Harris, M.D, an obstetric anesthesiologist from Baltimore, Maryland, who became the first anesthesiologist ever elected to the U.S. Congress on November 2nd in a decisive 55%-42% victory.

A total of 21 physicians were elected to Congress on November 2nd -- a net addition of six members of the profession. Here are the results of the elections:

Newly Elected to the House of Representatives

  • Andy Harris, MD (R, Md.), anesthesiologist
  • Mike Fallon, MD (R, Colo.), emergency physician
  • Larry Bucshon, MD (R, Ind.), thoracic surgeon
  • Dan Benishek, MD (R, Mich.), surgeon
  • Joe Heck, DO (R, Nev.), emergency physician
  • Nan Hayworth, MD (R, N.Y.), internist
  • Scott DesJarlais, MD (R, Tenn.), family physician

Re-elected to the House

  • Rep. Charles Boustany Jr., MD (R, La.), cardiovascular surgeon
  • Rep. Paul Broun, MD (R, Ga.), family physician
  • Rep. Michael C. Burgess, MD (R, Texas), obstetrician/gynecologist
  • Rep. Bill Cassidy, MD (R, La.), gastroenterologist/internist
  • Del. Donna M.C. Christensen, MD (D, Virgin Islands), family physician
  • Rep. John Fleming, MD (R, La.), family physician
  • Rep. Phil Gingrey, MD (R, Ga.), obstetrician/gynecologist
  • Rep. Jim McDermott, MD (D, Wash.), psychiatrist
  • Rep. Ron Paul, MD (R, Texas), obstetrician/gynecologist
  • Rep. Tom Price, MD (R, Ga.), orthopedic surgeon
  • Rep. Phil Roe, MD (R, Tenn.), obstetrician/gynecologist
  • Rep. Vic Snyder, MD (D, Ark.), family physician

Elected to the Senate

  • Rand Paul, MD (R, Ky.),ophthalmologist [son of Dr. Ron Paul]

Re-elected to the Senate

  • Sen. Tom Coburn, MD (R, Okla.), obstetrician/gynecologist

In the Senate, not up for re-election

  • Sen. John Barrasso, MD (R, Wyo.), orthopedic surgeon

We encourage readers to consider joining these 19 Representatives and 3 Senators two years from now – we need all the knowledge of health care issues that practicing physicians can bring to Congress.

 

With best wishes,

Tony Mira
President and CEO