Public Reporting: What Does It Mean for You?

I know I am wearing out the 2012 Medicare PFS without actually discussing the contents of most importance to the typical nephrology practice’s bottom line (actual fee schedule changes), but I want to review two more topics first. Today, it’s the CMS approach to the public reporting of quality data.

 

The Affordable Care Act (ACA) addressed a large number of issues, and one of those was the requirement to make quality measures publicly available. Historically, CMS has created similar sites that permit Medicare beneficiaries (and the general public) to compare a host of health care organizations. Sites available today include Hospital Compare, Dialysis Facility Compare, Nursing Home Compare and Home Health Compare. The intent is to create transparency for Medicare beneficiaries regarding quality of care. We could spend a lot of time arguing about the merits of this approach and the actual value delivered to patients; but since I only have your attention for a few minutes, I will let you know instead what’s coming down the pike for the nephrologist in regard to public reporting.

 

The ACA required that by no later than January 1, 2011, HHS develop a Physician Compare website. Two days before that deadline, CMS launched phase 1 of this program by leveraging the existing Physician and Other Health Care Professionals directory to create the foundation for Physician Compare. If you have not visited this website, please do so. If you are a provider, look yourself up and make sure the information displayed is accurate. Preliminary information to be posted here will include whether or not you successfully participated in the CMS PQRS, eRx and EHR Incentive programs. Board certification status will also be displayed. Ultimately this site will display actual performance data from PQRS measures and/or the Clinical Quality Measures from the EHR Incentive program. The 2012 PFS lays the groundwork for how CMS intends to proceed.

 

The ACA also requires that “no 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 information on physician performance publicly available through the Physician Compare website.” The 2012 PFS finalizes how CMS intends to meet this requirement.

 

Today there is a PQRS reporting option—the Group Practice Reporting Option (GPRO)—for practices that have more than 25 providers. CMS plans to use the quality data submitted by practices reporting PQRS measures via GPRO in 2012 to fulfill the public reporting requirement defined above. Practices participating in the 2012 PQRS program via GPRO must provide their consent to have their results displayed on the Physician Compare website in 2013. Note the results will be reported at the practice level. A list of providers in the practice will be available on the website but the performance metrics will be displayed at the practice level, not the individual provider level.

 

The PQRS objectives available for reporting via GPRO are largely primary care and preventive care facing objectives. Within this context I doubt there are many nephrologists reporting PQRS via GPRO. But this approach does provide us with a window into the future of transparency and “value-based purchasing.”

 

A final requirement of ACA related to public reporting is captured in this quote from the 2012 PFS final rule:

 

“We are required, under section 10331 (f) of the Affordable Care Act, to submit a report to the Congress by January 1, 2015 on the Physician Compare website developed, and include information on the efforts and plans to collect and publish data on physician quality and efficiency and on patient experience of care in support of value-based purchasing and consumer choice. Section 10331(g) of the Affordable Care Act provides that any time before that date, we may continue to expand the information made available on Physician Compare.

 

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 results.

 

For purposes of implementing a plan to publicly report physician performance, we plan to use data reported under the existing Physician Quality Reporting System as an initial step for making public physician ‘measure performance’ information on Physician Compare.”

 

The implications for the practicing nephrologist are clear. As you indentify quality measures to report, either through the PQRS program or the EHR Incentive program, you must recognize that your choice has potential impact beyond the program’s financial incentive. In years to come (perhaps as early as the 2013 reporting period) the performance scores for individual measures will begin to make their way into the public domain.

 

In my opinion, it is not too early to begin considering this new paradigm as you consider which measures to report to CMS. Public reporting of quality data is always a touchy subject. We’d love to know what you think about this topic.