PQRS Reporting Options Chart

PQRS Reporting Option

Group or Individual?

Reporting Requirements

Registration/Submission Timing/Process

Additional Information

Pathologist-Specific Considerations

Useful Resources

GPRO Web Interface + Clinician and Group Consumer Assessment of

Healthcare Providers and Systems (CG-CAHPS)

 

Group Only (25+ EPs)

Groups of 25-99 EPs: Report on all 18 pre-determined measures for a random sample of 218 patients identified via claims from January 1, 2014 through October 31, 2014

 

Groups of 100+ EPs: Report on all 18 pre-determined measures for a random sample of 411 patients AND all CG CAHPS survey measures via certified survey vendor

Reporting Mode: XML or manual data entry

 

CY 2014 PQRS GPRO Self-Nomination Deadline: September 30, 2014

 

Submission Window: Approx. 2 Months

FYI: CMS considered eliminating this reporting option for groups of 25-99 EPs in CY 2014 because it was not widely used by this group size in CY 2013

 

Funding Available: CMS will administer and fund the collection of CG-CAHPS data for groups of 100+ EPs only

 

Public Reporting: 2014 performance data and patient experience (CG-CAHPS) publicly reported on Physician Compare

Somewhat attractive option for multi-specialty groups of EPs containing pathologists with no applicable measures

 

Pathologists’ lack of direct patient interaction may make it difficult to report on CAHPS measures

 

CMS “2014 Physician Quality Reporting System (PQRS):Implementation Guide”

·         Group Practice Reporting Option via Web Interface: Page 12

·         Appendix B: 2014 PQRS Participation Decision Tree

·         Appendix E: PQRS GPRO Web Interface Process

 

CMS GPRO Web-Interface Web Page

 

2014 PQRS GPRO Requirements

 

2013 PQRS GPRO ACO CAHPS Overview

 

TABLE 80, Page 1107 of CY 2014 PFS Final Rule: Measures in the GPRO Web Interface for 2014

 

A list of certified CAHPS survey vendors is not yet available

 

Claims-Based

Individual Only

Report all applicable measures for at least 50 percent of Medicare Part B patients seen during the reporting period: 1-9 measures (covering 1-3 NQS domains) to earn incentive payment and 1-3 measures covering at least 1 NQS domain to avoid payment adjustment

No Registration Needed: Individual EPs do not need to sign-up or pre-register in order to participate in PQRS

 

Reporting Mode: EPs must report concurrently with claims submission

 

Submission Timeline Guidance: “Claims processed by the Carrier or A/B MAC must reach the national Medicare claims system data warehouse (National Claims History file) by February 27, 2015 to be included in the analysis. Claims for services furnished toward the end of the reporting period should be filed promptly. Claims that are resubmitted only to add QDCs will not be included in the analysis.”- CMS

This option is the only cost-free option

 

CMS is eliminating the option to report measures groups via claims for CY 2014

 

Important Clarification: This option is not to be confused with the “administrative claims-based reporting option,” which was only available in 2013 as a means of avoiding a 2015 payment adjustment

 

Public Reporting: CMS will post individual measures (20 possible) that are in line with those reported by groups through the GPRO web interface on the Physician Compare Website in CY 2015

 

Historically, the most attractive option for pathologists (other than the administrative claims-based option in 2013)

CMS “2014 Physician Quality Reporting System (PQRS): Implementation Guide”

·         Reporting via Claims: Page 14

·         Appendix B: 2014 PQRS Participation Decision Tree

·         Appendix C: Satisfactory Reporting via Claims Scenario

·         Appendix D: CMS-1500 Claim PQRS Example

·         Appendix H: PQRS Claims-Based Process

 

CMS Claims-based Reporting Web Page

 

2014 PQRS Individual Claims Registry Measure Specification Supporting Documents

·         2014 PQRS Measure Specifications Manual for Claims and Registry Reporting of Individual Measures

·         2014 PQRS Measures Specification Release Notes: Outlines 2014 updates made to the 2013 PQRS Measures

·         2014 Quality Data Code (QDC) Categories

·         2014 PQRS Single Source Code Master

 

2013 PQRS CMS 1500 Claim Example

 

2013 PQRS Claims Reporting Made Simple

 

Registry

Both Individual and Group

For Individual Measures: Report all applicable measures for at least 50 percent of Medicare Part B patients seen during the reporting period: 1-9 measures (covering 1-3 NQF domains) to earn incentive payment and 1-3 measures covering at least 1 NQF domain to avoid payment adjustment

 

For Measures Groups: Report at least one measures group, AND report each measures group for at least 20 patients, a majority of which must be Medicare Part B FFS patients.

Group Practice Registration Deadline: Group practices reporting as a group must register for their selected reporting method by September 30, 2014

 

Submission Mode: Registry submits data on behalf individual EPs and groups of EPs

 

 

This is the only remaining option to report measures groups

 

Reporting Flexibility: There is a 6-month reporting option to report on measures groups under this option

 

Public Reporting: Registry measures that are also available for reporting via the GPRO web-interface will be publically reported on Physician Compare in CY 2015

 

 

CY 2013 Registry Vendors with ability to report on pathology-specific measures: 31/70 have the capability to report on at least one of the five available pathology-specific PQRS measures

·         22/31 have the capability to report on all five available pathology-specific measures

·         22/31 offer GPRO reporting via registry

 

 

 

CMS “2014 Physician Quality Reporting System (PQRS): Implementation Guide”

·         Reporting via Qualified Registry: Page 9

·         Appendix B: 2014 PQRS Participation Decision Tree

·         Appendix F: PQRS Qualified Registry-Based Process

 

2014 Registry Reporting Made Simple

 

CMS PQRS Registry Reporting Option Web Page

 

2014 PQRS Individual Claims Registry Measure Specification Supporting Documents

·         2014 PQRS Measure Specifications Manual for Claims and Registry Reporting of Individual Measures

·         2014 PQRS Measures Specification Release Notes: Outlines 2014 updates made to the 2013 PQRS Measures

·         2014 Quality Data Code (QDC) Categories

·         2014 PQRS Single Source Code Master

 

2014 PQRS Measure Groups Specifications, Release Notes, Getting Started with 2014 PQRS Measures Groups, 2014 Quality-Data Code Categories, and 2014 PQRS Measures Groups Single Source Code Master

 

2014 Registry Vendor Criteria

 

2014 PQRS GPRO Requirements

 

2013 Qualified Registry Vendors (will likely qualify for 2014 plus a few additions)

 

Direct EHR product that is CEHRT and EHR data submission vendor that is CEHRT

Both Individual and Group

Report all applicable measures for at least 50 percent of Medicare Part B FFS patients seen during the reporting period: 1-9 measures (covering 1-3 NQS domains) to earn incentive payment and 1-3 measures covering at least 1 NQS domain to avoid payment adjustment

Group Practice Registration Deadline: Group practices reporting as a group must register for their selected reporting method by September 30, 2014

 

Submission Frequency: Annual submission

 

Submission Mechanism: Option 1: Direct EHR Vendor; Option 2: EHR Data Submission Vendor

 

Submission Mode: Data submitted to CMS must be transmitted using the Quality Data Model (QDM)-based Quality Reporting Documentation Architecture (QRDA) Category I or QRDA Category III formats

 

Submission Deadline: EPs and group practices must submit final EHR reporting files with quality measure data, or ensure that their EHR Data Submission Vendor submits files by the data submission deadline of February 28, 2015, to be analyzed and used for 2014 PQRS EHR measure calculations

 

Beginning in 2014, this option is available for group reporting*

 

EHR Incentive Program Alignment: EPs and group practices may meet the Clinical Quality Measure (eCQM) component for the Medicare EHR Incentive Program if they participate via the PQRS EHR-based reporting method

 

Public Reporting: EHR measures that are also available for reporting via the GPRO web-interface will be publically reported on Physician Compare in CY 2015

 

This is likely not a viable option for pathologists, who are unable to participate in the EHR Incentive program

CMS “2014 Physician Quality Reporting System (PQRS): Implementation Guide”

·         Reporting via EHR: Page 7

·         Appendix B: 2014 PQRS Participation Decision Tree

·         Appendix E: PQRS EHR-Based Process

 

Electronic Clinical Quality Measures (eCQM) Library

 

CY 2014 eCQMs

 

2014 PQRS GPRO Requirements

 

 

 

Qualified Clinical Data Registry (QCDR)

Individual Only

Report all applicable measures for at least 50 percent of Medicare Part B FFS patients seen during the reporting period: 1-9 measures (covering 1-3 NQS domains) to earn incentive payment and 1-3 measures covering at least 1 NQS domain to avoid payment adjustment; Report at least 1 outcome measure to earn an incentive payment

 

Note: QCDRs must calculate the composite score for CMS and provide the formula used for calculation

 

“Satisfactory Participation” Submission: For the CY 2014 reporting period only, the QCDR must provide CMS with a list of EPs (with TIN/NPI info) that participated in and reported quality data to the QCDR, in order to determine satisfactory participation for the 2014 PQRS incentive and 2016 Payment Adjustment. This is because CMS may not yet have the capacity to receive information on newly customized QCDR measures.

 

Self-Nomination Registration Deadline: QCDRs seeking to participate their registrants in PQRS for a given CY must self-nominate to do so by January 31st of that CY

 

Validation Strategy Submission Deadline: QCDRs seeking to participate their registrants in PQRS for a given CY must submit a validation strategy to CMS and post their measures on their website by March 31 of that CY

 

Quality Measures Submission Deadline: QCDRs must submit quality measures data to CMS no later than the last Friday occurring 2 months after the end of the respective reporting period (that is, February 27, 2015 for reporting periods occurring in 2014)

·         The QDCR is not allowed to re-submit quality measures data on behalf of its EPs if CMS discovers the QCDR submitted inaccurate data

 

Submission Mode: The QCDR must submit measures to CMS via an XML format and, in the future, CMS hopes to allow QCDRs the option to submit electronic Clinical Quality Measures (eCQMs) via QRDA III format

 

 

Deadline for Providing Evidence of Successful Results: QCDRs must send evidence of successful results to CMS by June 30th of the year following the reporting period

 

 

New reporting option for 2014*

 

“Qualified Clinical Data Registry (QCDR)”: A CMS-approved entity (such as a registry, certification board, collaborative, etc.) that collects medical and/or clinical data for the purpose of patient and disease tracking to foster improvement in the quality of care furnished to patients

 

Reporting Flexibility: This option does not require reporting on PQRS measures nor does it require that measures are reported solely for Medicare Part B FFS patients. EPs will be able to report up to 20 non-PQRS measures for a broader patient population, including non-Medicare patients

 

Non-PQRS Measures Requirements: QCDRs must report on a set of measures from one or more of the following categories: CG-CAHPS; NQF endorsed measures; current PQRS measures; measures used by boards or specialty societies; and measures used in regional quality collaboratives

 

 

This will not be an available option for CY 2014 and in order for this to be an option in CY 2015, a QCDR would have to be up and running with 50 participants by January 1, 2014

 

The QCDR’s requirement to report on one outcome measure is not likely feasible for pathologists

CMS “2014 Physician Quality Reporting System (PQRS): Implementation Guide”

·         Satisfactorily Participating via Qualified Clinical Data Registry (QCDR): Page 11

·         Appendix B: 2014 PQRS Participation Decision Tree

 

2014 Qualified Clinical Data Registry Participation Made Simple

 

2014 Physician Quality Reporting System: Qualified Clinical Data Registry Data Submission Criteria

 

A list of CMS-designated QCDRs will be available on the CMS PQRS website in the fall of 2014

CMS-certified survey vendor + qualified registry, direct EHR product, EHR data submission vendor, or  GPRO web interface

Group Only (25-99 EPs)

Report all 12 CG CAHPS survey measures via a CMS-certified survey vendor, AND report at least 6 measures covering at least 2 of the NQS domains using a qualified registry, direct EHR product, EHR data submission vendor, or GPRO web interface

Group Practice Registration Deadline: Group practices reporting as a group must register for their selected reporting method by September 30, 2014; the group practice  must indicate its intent to report the CG  CAHPS survey when it registers to  participate in the PQRS via the GPRO

 

Patient Attribution Methodology: CMS assigns beneficiaries to a group based  on whether the group provided the  plurality of primary care services

 

Survey Administration: Survey administered at the close of the PQRS registration periodby a certified survey vendor  on behalf of the group practice for a  sample of the group’s assigned  beneficiaries

 

Submission Process: The data collected on these measures will be submitted annually on behalf of the group practice by the certified survey vendor

 

 

 

 

New group reporting option for 2014*

 

Certified survey vendor: A

vendor that is certified by CMS for a particular program year to transmit survey measures data to CMS

 

Certification requirements: To obtain CMS certification, vendors are required to undergo training, meet CMS standards on how to administer the survey, and submit a quality assurance plan.

 

Associated Costs: CMS will not bear the cost of administering the CG-CAHPS

Survey for groups of less than 100 EPs under this reporting option

 

Explanation of Requirements: The CG CAHPS summary survey modules will be considered the equivalent of 3 individual measures covering 1 NQS domain. Therefore, group practices that register for this method of reporting will need to report on at least 6 additional measures covering at least 2 additional NQS domains via qualified registry, direct EHR product, or EHR data submission vendor in order to avoid the PQRS payment adjustment and earn the PQRS incentive payment.

 

Survey Report: CMS will provide each group a  detailed report about the results of the  survey

 

Public Reporting:Results posted on the Physician Compare Website

Pathologists’ lack of direct patient interaction may make it difficult to report on Patient Experience of Care (CAHPS) measures

 

Because CMS assigns  beneficiaries to a group based on the  provision of primary care services, this  survey is not an appropriate option for  groups of physicians that do not  provide primary care services

 

CMS “2014 Physician Quality Reporting System (PQRS): Implementation Guide”

·         Reporting via Certified Survey Vendor: Page 13

·         Appendix B: 2014 PQRS Participation Decision Tree

 

2013 PQRS GPRO ACO CAHPS Overview

 

2014 PQRS GPRO Requirements

 

 

 


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