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After Years of Communicating PQRS Concerns, ASCP Proposes a Potential Solution

Wednesday, December 18, 2013

Since the creation of the Physician Quality Reporting System (PQRS) in 2007, ASCP has been committed to educating our members on program requirements and communicating to the Centers for Medicare and Medicaid Services (CMS) when program requirements do not meaningfully align with the pathology specialty. However, after years of urging CMS to slow program advancement, develop more pathology-specific measures, and exempt pathologists with no applicable measures from negative payment adjustments, ASCP is shifting to an even more proactive advocacy approach.

On Dec. 3, ASCP submitted a proposal to CMS in response to pathologists’ difficulty in successfully participating in PQRS. The proposal requested the extension and modification of the PQRS: Maintenance of Certification (MOC) Program Incentive.

 ASCP proposed that fulfillment of the PQRS: MOC Program Incentive requirements fulfill baseline PQRS requirements, rather than qualify the physician for an additional incentive payment only once PQRS requirements have been met.

ASCP submitted this proposal to CMS on behalf of its members and their patients. The Society reinforced the laboratory’s role as a central hub for patient testing, whether within a hospital or as an independent facility within a community. Hence, contrary to the granular level of PQRS quality measurement, pathologists are innately required to have a broad reach when it comes to their quality improvement efforts. As such, ASCP encouraged CMS to begin to recognize and reward our members’ large-scale efforts, which have the enhanced capability to generate large-scale impact on quality.

ASCP finds the extension and modification of the PQRS: MOC Program Incentive a feasible and effective approach to enhancing PQRS participation and/or quality for several reasons outlined in the proposal. The MOC program’s widespread adoption rate, patient and provider support, and reputation for driving quality all provide evidence in support for the Society’s proposal. ASCP also believes that MOC may provide a structured forum for CMS to effectively assess quality for additional specialties facing difficulty successfully participating in PQRS.

The Proposal is divided into four main sections:

Current experience and future concerns regarding pathologists’ participation in quality reporting programs

  • Currently, pathologists are unable to participate in the Electronic Health Record (EHR) Incentive program and the electronic-prescribing (eRx) program
  • In 2011, nearly 63 percent of pathologists participating in Medicare Part B were unable to successfully participate in PQRS
  • CMS increased the number of measures required to achieve a 2014 payment incentive from three to nine, while pathologists only have five pathology-specific measures available

The innate incongruity of pathology-specific traits and quality reporting program measures

  • Current PQRS measures assess performance at the analytic phase, while the pathologist’s role tends to be most essential during the pre- and post-analytic phases
  • Patient health outcomes are difficult to trace back to the point of accurate diagnosis
  • Current pathology-specific PQRS measures are not only condition-specific, but also test-specific – meaning it could be years before all subspecialists have applicable measures
  • Contrary to the granular level of PQRS measures, pathologists’ quality improvement efforts broadly span across laboratories and hospitals and are thus not easily captured on billing claims
  • While PQRS measures must be auditable via Medicare Part B claims, pathologists routinely provide services for both inpatients and outpatients

Results from an ASCP-original quantitative analysis, estimating the cumulative negative impact on pathologists’ reimbursement due to their inability to participate in multiple quality reporting programs

  • From 2007 through 2014, an individual pathologist unable to participate in all quality reporting programs since the introduction of PQRS will have experienced an average cost estimated at 8 percent (approximately $65,000) of his/her total Medicare Part B allowed charges
  • Aggregated across the pathology community participating in Medicare, this cost is estimated at approximately $630 million
  • These estimates do not take into consideration additional stressors on Medicare reimbursement, such as sequestration; failure to extend the EHR incentive program hardship exemption; the threat of the Sustainable Growth Rate; and the cost of gifting EHRs

Evidentiary support that our proposal offers a viable option for CMS to meaningfully evaluate and reward pathologists’ quality improvement efforts

  • Physicians increasingly participate in MOC and have acknowledged MOC’s benefits
  • Patients understand and value MOC
  • MOC already has a system in place for developing/validating specialty-specific quality measures
  • Investment in MOC reporting infrastructure is investment in PQRS reporting infrastructure
  • MOC is evidence-based and a proven quality enhancer
  • The Institute of Medicine supports MOC as a chief quality indicator
  • MOC requirements align with Congress’s recently proposed “clinical practice improvement activity” category, proposed for inclusion in a compulsory quality reporting program

The American Board of Pathology has voiced support for this proposal and now ASCP is working with officials in CMS and Congress in pursuit of potential implementation. We will keep our members informed accordingly.