PQRS 2012

As I mentioned last week, the 2012 Medicare PFS contains a little something for everyone. This is particularly true for those of you who suffer from insomnia. Today, let’s explore what’s in store for PQRS next year as “succinctly” outlined in roughly 200 pages of the PFS final rule.

 

Remarkable as it may seem, 2012 will be the 6^th year of the PQRS program. As 2012 rolls around, a number of providers contemplating the PQRS program will also be interested in demonstrating meaningful use. In contrast to the eRx program we discussed last week, a provider demonstrating meaningful use may also participate in the PQRS program and receive the incentive if successful. The incentive for 2012 falls to 0.5% of the provider’s Medicare Part B allowable for the entire calendar year. Data from 2009 suggests this should be roughly $1,500 for the average nephrologist. In our experience with the PQRS Registry, the standard deviation here is wide.

 

The Song Remains the Same

Classic rock fans in the audience will appreciate the fact that quite a bit of the PQRS “song” remains the same for the 2012 reporting year. Specifically, providers will have the opportunity to convey participation to CMS via the same three existing mechanisms today: through claims, via a CMS qualified Registry, and, in some cases, directly from a qualified EHR. In addition providers may either report three individual PQRS measures or they may elect to report a PQRS Measures Group. A Measures Group consists of four or more individual PQRS measures, each of which share a common denominator. Several features of the program that debuted in 2011 will carry over into the 2012 program as well:

• All patients reported must be Medicare Part B beneficiaries.
• A zero percent performance score will not be counted as a reported measure.
• The reporting threshold for claims-based reporting is 50% while the registry reporting target remains 80%.
• Reporting 30 patients for a Measures Group (historically the most common choice among nephrologist) remains on the menu of choices.

Part of the Song has Changed

As is usually the case this time of year, CMS has tweaked the system slightly and some of these changes will impact nephrology. Of negligible consequence, the six-month reporting period appears to be on the way out. In 2012, it is only available to providers reporting a Measures Group through a Registry. My sense is this is another example of CMS’ drive to align the PQRS program with the EHR Incentive Programs Clinical Quality Measures. Of additional interest, CMS has dropped three of our nephrology measures. The flu vaccine measures for adult ESRD and CKD as well as the related pediatric ESRD measure (measure numbers 79, 135 & 175 respectively) will be retired in 2012.

 

CMS has also made a cosmetic naming change for the ESRD and CKD related measures. Each will now be entitled “Adult Kidney Disease:…”. Within this context, the popular CKD Measures Group is now the Adult Kidney Disease Measures Group. Even more interesting is it is now made up of the following four individual measures:

• 121—Adult Kidney Disease: Laboratory Testing (Lipid Profile)
• 122—Adult Kidney Disease: Blood Pressure Management
• 123—Adult Kidney Disease: Patients on Erythropoiesis-Stimulating Agent Hemoglobin Level > 12.0 g/dL
• 110—Preventive Care and Screening: Influenza Immunization

The 2015 Adjustment

I sort of feel like scrooge laying this one on you, but I want to leave you with one final note as we enter the Holiday season. Contained within the 2012 PFS is a window into yet another “adjustment” from our friends at CMS. As you may recall, the PQRS program also has a penalty phase set to begin in 2015. The 2012 PFS has defined calendar year 2013 as the 2015 PQRS adjustment reporting period. If you do not successfully participate in the PQRS program during 2013, your 2015 Medicare PFS will be reduced by 1.5%. We have heard this tune before with the eRx incentive program. CMS has left the window open and may revisit this issue next year. Stay tuned and try to enjoy the music. Happy Thanksgiving.