In a recent blog post I described some of the changes in store for PQRI in 2011. The 2011 Medicare PFS also contains information of interest related to the public reporting of quality data. Many of us are familiar with CMS web sites such as Hospital Compare and Dialysis Facility Compare. The intent of these sites is to create a venue within the public domain where Medicare beneficiaries can easily compare quality outcomes between hospitals or dialysis facilities respectively. The value of these sites together with the validity of the data have been debated elsewhere, but regardless of where you find yourself within this debate it is important to note the concept is being expanded to the individual physician.
The Affordable Care Act (ACA) makes a number of changes to the PQRI program. One of these is the requirement to establish a Physician Compare website by January 1, 2011. The 2011 Medicare PFS includes a number of comments and responses related to this process. What is clear is HHS intends to report the names of eligible professionals who were successful e-prescribers and those who participated in the 2011 Physician Quality Reporting System (PQRS™) on the Physician Compare web site. Related to PQRS™, the intention is to post the names of those providers who:
1. Submit data on the 2011 Physician Quality Reporting System quality measures through one of the reporting mechanisms available for the 2011 Physician Quality Reporting System;
2. Meet one of the satisfactory reporting criteria of individual measures or measures groups for the 2011 Physician Quality Reporting System; and
3. Qualify to earn a Physician Quality Reporting System incentive payment for covered professional services furnished during the applicable 2011 Physician Quality Reporting System reporting period.
Effectively 2011 will be a time of public reporting of a physician’s participation in these programs. The rule goes on to state; however, that HHS is required to report quality outcomes by January 1, 2013. Quoting from the 2011 Medicare PFS final rule:
“We did not propose to make performance information publicly available at either the group practice or individual level for 2011 Physician Quality Reporting System. However, we note that section 10331 of the ACA requires that not later than January 1, 2013, and with respect to reporting periods that begin no earlier than January 1, 2012, we implement a plan for making publicly available through Physician Compare, information on physician performance, including measures collected under the Physician Quality Reporting System. Consistent with section 10331 of the ACA, we expect, in the future, to publicly report performance information based on the Physician Quality Reporting System.”
What are the practical implications for the nephrologist? I think there are several. The existing PQRI program provides incentives to report quality data. Each measure does contain a performance score; however, the provider with the worst performance score is paid the same incentive as the provider with the best performance score. This incentive structure may influence the nephrologist’s selection of measures to report (a provider may select a measure to report on based on the ease of reporting instead of selecting a measure whose performance outcome more closely reflects the impact of the care provided to his or her patients). Future participants in the program should recognize the implications of public reporting as they select measures to report.
The public reporting of quality data at the individual provider level will generate substantial discussion in 2011. Organized medicine will certainly have a seat at the table as the specific details are finalized. CMS is putting its toe in the water next year by reporting participation in PQRS™, but in 2012 they will report performance data. We need to pay very close attention to the evolving realm of public reporting as the details become clear over the months ahead.
What do you see as the implications of public reporting of quality data at the individual provider level? How will this program affect your participation in PQRS™? We’d love to hear your thoughts on this change to the PQRS™ program.
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