2013 Resolutions

With the first week of 2013 coming to a close, I know many of you are well on your way to fulfilling your 2013 resolutions. This year introduces something new for several of the CMS programs we track in the Acumen blog. As the excitement surrounding the fiscal cliff and the “Doc Fix” fades to black, let’s examine what CMS has in store for us this year.

 

Payment Adjustment Reporting Period

 

Last year a large number of providers felt the pain of the CMS eRx penalty. The eRx incentive program was the first of the “big four” to levy a penalty by reducing a provider’s Medicare Part B allowable by 1.0% in 2012. The eRx program provides substantial insight, as both the PQRS and the EHR incentive program (Meaningful Use) will use a similar methodology to levy penalties in 2015. With eRx we learned a new phrase, “payment adjustment reporting period.” In my mind’s eye, I have come to think of the payment adjustment reporting period as a surveillance period. Due to existing challenges within the Medicare claims process, these programs must survey provider behavior well in advance of the penalty year in order to determine who is subject to the program’s penalty. This year represents the payment adjustment reporting period for both the PQRS and the meaningful use programs in 2015.

 

PQRS

 

Now in its seventh year, PQRS is the granddaddy of the physician-facing CMS incentive programs. Successful participation in the PQRS program in 2013 accomplishes two important goals for the provider:

1. A 0.5% “bonus” on the provider’s 2013 Medicare Part B allowable. (If history repeats, providers may expect to receive this bonus in the fall of 2014.)
2. Avoiding the 1.5% penalty, which will be levied upon providers in 2015 if they are deemed not to be successful participants in the program. Unlike the bonus, the penalty is applied in real time, as was the case with last year’s 2012 eRx penalty. That is to say, nephrologists facing the 2015 PQRS penalty will receive 98.5% of the Medicare part B physician fee schedule for services rendered in 2015.

We may see other opportunities emerge to avoid the 2015 PQRS penalty, but the simplest approach to date is to successfully participate in the 2013 program.

 

Meaningful Use

 

It’s hard to believe, but 2013 will be year three for some providers. Time flies while you are having fun does not seem apropos in this context. For the majority of providers who have not yet jumped on this bandwagon, it is important to note that participation in the CMS EHR incentive program in 2013 is one of the principal ways to avoid the 1.0% penalty that will be levied in 2015. As with PQRS, the surveillance period for 2015 is this year. There are several other ways to avoid this penalty, but many will do so by demonstrating meaningful use in 2013.

 

Physician Value-Based Payment Modifier

 

Last, but certainly not least on our list of resolutions for 2013 is a newcomer on the block. Earlier I mentioned the “big four.” Readers of this blog are likely very familiar with eRx, PQRS and meaningful use. The sleeping giant is the physician VBP. (I know everyone is looking forward to learning a new acronym.) The physician VBP is the latest edition in CMS’ drive to transform itself from a passive payer to an active purchaser of quality healthcare. While this may sound like worn-out rhetoric, let me assure you this program will change our world.

 

Thankfully, the government is dipping its toe into the water by only exposing large practices (groups with more than 100 providers) to this program for the first two years. This means most nephrologists can watch from the sidelines and gain experience by living vicariously through the eyes of the large multi-specialty groups. As we have seen with the other incentive programs, provider behavior is surveyed well in advance of the incentive phase of the program. This year is the performance period for the application of the 2015 physician value-based payment modifier for the large practices. The quality component of this program is tied to PQRS performance scores—yet another good reason to gain some experience with PQRS.

 

Resolve to avoid the penalties

 

The ball has dropped and resolutions have been made. Some of you, however, may wish to consider adding a few more to your list. Participating in PQRS is low hanging fruit and doing so this year will very much be worth your while. Meaningful use is a much higher hurdle to clear, but if you intend to do so, one could argue there is no better year to start than 2013. And, finally, you’ll want to pay close attention to the new kid on the block. Sticking your head in the sand while the large groups pay the piper is not a wise strategy. We need to heed the lessons learned with physician VBP, as everyone will face this music in the years ahead.