The 2011 Medicare Physician Fee Schedule (PFS) mentioned the Health and Human Services requirement to establish a Physician Compare website by January 1, 2011. This deadline was one of several contained in the Affordable Care Act (ACA). I have just finished reading pertinent sections of the proposed 2012 Medicare PFS (another useful read for those of you suffering with insomnia) and will summarize those components related to the intersection of nephrology and health IT over the next few weeks. With the Physician Compare deadline in the rearview mirror, let’s examine how CMS proposes to tackle the ACA requirements related to Physician Compare.
It is clear from the language in the 2012 proposal that this train is moving slower than originally anticipated. As you may recall, the intent of Physician Compare is to provide Medicare beneficiaries with a publically available website that displays information about physicians enrolled in the Medicare program, which of course would include practically every nephrologist seeing patients in this country. Along these lines, CMS already provides Hospital, Dialysis Facility, Nursing Home and Home Health Compare websites.
Physician Performance Becomes Publically Available
On December 30, 2010 (with almost 48 hours to spare!), the existing Physician and Other Health Care Professionals directory was updated with what is considered to be the first step in providing information on the quality of services delivered by providers. You may be surprised to learn this initial foray into reporting physician quality performance metrics is limited to displaying whether or not you successfully participated in the 2009 PQRI program (recently renamed PQRS or the CMS preferred moniker Physician Quality Reporting).
By January 1, 2013 (another deadline created by ACA for HHS), Physician Compare must make information regarding physician performance publically available. This performance information must not be collected prior to calendar year 2012. This is intended to be part of the planned transition to “value-based purchasing.” Quoting from the proposed rule, “We believe section 10331 of the Affordable Care Act supports our overarching goals to foster transparency and public reporting by providing consumers with quality of care information to make informed decisions about their health care, while encouraging clinicians to improve on the quality of care they provide to their patients. In accordance with section 10331 of the Affordable Care Act, we intend to utilize the Physician Compare website to publicly report physician performance.”
Next Steps for Physician Compare
This type of language keeps some folks up late at night. However, as always, the devil is in the details. Publically reporting physician-level data appears to be a future intent, but an actual date is nowhere to be found in this proposed rule. The proposed 2012 Medicare PFS goes on to describe proposed next steps for Physician Compare. The proposed rule outlines the following:
- Step 1—Publish the names of the providers who successfully participated in the 2009 PQRI program. This has been accomplished.
- Step 2—Update the public website in 2011 and 2012 with the names of providers who:
– Are successful e-prescribers.
– Participated in the EHR Incentive Program (aka Meaningful Use).
– Provide links to specialty boards permitting review of the physician’s board certification status.
- Step 3—Make an actual move toward public reporting of physician performance information. Practices that elect to report PQRS data in 2012 via the Group Practice Reporting Option (affectionately known as GPRO) will be compelled to agree in advance to have their performance results publically displayed on Physician Compare in 2013.
The GPRO option for reporting PQRS rolled out last year and is designed, in my opinion, to appeal to large primary care or multi-specialty practices. GPRO is a reasonable place to start as every practice that reports via GPRO must report the same PQRS individual quality measures. The proposed rule goes on to state that the publically reported performance scores will be tied to the practice not the physician (although the physician members of the practice will be posted on the site).
What This Means for Nephrologists
Where does this leave the typical nephrologist? I am unaware of nephrologists who have taken the GPRO path to reporting PQRS, but if you have, please post a comment about your experience. The practicing nephrologist should finish reading this post and immediately go to the Physician Compare surrogate and look for your name. Make sure the information here is accurate. If it is not, try to have it corrected.
It is clear from the language in this proposed rule and others I have read that the PQRS measures and the CQMs within the Meaningful Use program are in the public reporting crosshairs. Historically some providers may have viewed these simply as pay-for-reporting programs. Do not fall into this trap. Pay attention to your performance scores as they may some day make it into the public domain. Based on what I have read, 2011 data remains outside of public scrutiny, but I would pay close attention to what you choose to report in 2012. The Physician Compare train has indeed left the station, and although it is moving slowly, it will not stop.