The Physician Quality Reporting System

This time of year bears witness to many changes. The autumn foliage has come and gone, the Cowboys and Vikings will finish the season with new coaches, and PQRI has a new name. Okay, perhaps these three have nothing in common, but this week I thought I would review the changes we will see with PQRI in 2011. First the name change. The Affordable Care Act (ACA) set the stage for a number of changes within the health care system. Among many other things the ACA brings permanence to the physician quality reporting initiative. Reflecting this permanence CMS has dropped the word “initiative” and renamed the program the Physician Quality Reporting System (although CMS would prefer to avoid a new acronym it is hard to resist the allure of PQRS). Beyond inconveniencing a number of companies with stacks of PQRI marketing materials, what impact can we expect within the nephrology community?

 

First, the permanence of the program is further codified in the 2011 Medicare PFS. Reminiscent of the CMS e-prescribing program, PQRS employs a classic CMS carrot-and-stick approach to financial incentives. Providers successfully reporting PQRS in 2011 will receive an incentive equal to 1% of their eligible Medicare part B allowable charges for services rendered during 2011. The incentive then falls to 0.5% in 2012, 2013 and 2014. Providers not participating in PQRS will face penalties starting in 2015. As with e-prescribing, the PQRS penalty is expressed as an adjustment in the providers’ Medicare part B physician fee schedule. Providers not participating in PQRS in 2015 will see their Medicare PFS adjusted down by 1.5% with the penalty rising to 2% in 2016 and beyond.

 

Participation from a nephrology perspective has a couple of new wrinkles:

 

• Reporting the popular CKD measures group for 30 patients will now require all 30 patients to be part B beneficiaries. This may create challenges for certain practices with limited numbers of elderly late-stage CKD patients.

 

• Measure 135 (flu vaccine in stage 4 or 5 CKD patients) is no longer part of the CKD measures group, reducing the total number of measures in this measures group to four.

 

• Pediatric nephrologists will be disappointed to find measure 174 (Pediatric ESRD: Plan of Care for Inadequate Hemodialysis) has been retired for 2011.

 

• CMS has lowered the percentage targets for successfully reporting individual measures and measures groups via claims to 50%. The target for both remains 80% when reporting via a registry.

 

Nephrologists participating in the CMS EHR incentive program (meaningful use) may concurrently participate in PQRS. CMS is working towards aligning PQRS with the clinical quality reporting required by the EHR incentive program, but until this occurs nephrologists have the opportunity to participate in both programs. PQRS also brings important implications for public reporting of quality data, a change I will review in a future post.