Read this blog even if you are not a Doctor of Podiatric Medicine — it has important information about how to streamline your quality reporting requirements beginning in 2014. The unification of Clinical Quality Reporting across the Physician Quality Reporting System (PQRS, formerly PQRI) and Meaningful Use (MU) programs will help many doctors avoid penalties related to lack of participation in the PQRS program.
Quick Read — CMS is working on aligning the Meaningful Use and PQRS quality reporting programs. In 2014 your EHR vendor will be able to handle the measurement and reporting for both programs. For certain specialties, such as Podiatric Medicine, CMS must make changes to add more measures to the PQRS program for certified PQRS EHR submitters. We believe that the APMA® is working with Medicare to provide such a solution.
Eligible Professionals (EPs) are required to report on specified clinical quality measures, in order to qualify for incentive payments under the Medicare and Medicaid EHR Incentive Programs in both Stage 1 and Stage 2. In addition, physicians have been incentivized to participate in the CMS sponsored PQRS program, although incentives are waning and penalties are on the near horizon. When the Meaningful Use Stage 1 rule was passed it did not align its quality program with the PQRS program, although many of the measures are similar. Each program requires a separate and distinct workflow, even though they are both administered by CMS, increasing the cost of participation for most providers.
In Stage 2 of Meaningful Use, the government has proposed certain methods that may simplify the reporting of quality measures by unifying important components of both programs, although for certain specialties we are unsure whether they will be able to leverage these new, more efficient unified workflows.
The first step toward simplification involves the measurement of Clinical Quality Measures (CQMs). In Stage 2 of Meaningful Use, the proposed set of clinical quality measures will align with the PQRS program, for example the “smoking cessation measure” in the EHR incentive program will be calculated the same way when compared to the PQRS program. In 2014 EPs and EHR vendors will finally have a single method to measure the data for a specific measure.
The next step that we believe is a critical upgrade from the current method is the unification of reporting CQMs. We define unification in this context as a single method of collection and submission on behalf of the provider via their EHR.
Currently the PQRS system has 3 major ways to report results to the government:
- The Claim Method — submit CQM related “G” codes in your claim as zero dollar charges
- The Registry Method — submit data to a CMS approved registry and they submit the CQM data for you (the registry typically charges approximately $300.00)
- The EHR Method — your EHR submits the CQM data to CMS for you
Note: The least successful method of participating in the PQRS program is the claim method, because the data (G codes) must be entered on the claim form at the time of claim submission. This method is tedious and often results in failure.
Note: The PQRS EHR method is not aligned with Stage 1 Meaningful Use. In Stage 1 of Meaningful Use, reporting of CQM data is via a web interface on the CMS website at the time the provider attests to the rest of the MU measures (no file submission is required). Reporting CQMs during the attestation process is required even if your EHR vendor submitted a PQRS file to CMS for you — 2 programs and 2 distinct processes.
With regard to EHR reporting of CQM data there are 2 important changes in 2014:
- In Stage 2 of meaningful Use, file submission is required and attestation on the CMS website will no longer be necessary.
- EHR vendors that are approved by CMS for the PQRS program and that provide certified EHR technology can create both files for the participating provider (the EHR MU and PQRS file). Since the measures will be aligned, the EHR can create and submit both files for the EP.
CMS commented as follows in the Stage 2 proposed rule:
“We are committed to aligning quality measurement and reporting among our programs… Our alignment efforts focus on several fronts including choosing the same measures for different program measure sets, standardizing measure development and specification processes across CMS programs… We believe the alignment options for PQRS/EHR Incentive Program proposed in this rule are the first step towards such a vision.”
One of the issues that may make it more difficult for certain specialties to participate in this new streamlined approach would be the inclusion of not enough CQMs that apply to a particular profession for all methods of PQRS submission. A good example of a profession that has very few CQMs that universally apply to their profession is the practice of Podiatric Medicine. As a proud Corporate Partner of the APMA and with the awarding of the Seal of Acceptance to MediTouch EHR®, we now have many DPMs that use our system. On behalf of our user base we are now tracking how the government implements quality reporting for DPMs.
Currently the APMA recommends that DPMs report the following 3 PQRS measures via the claim method (at least 3 measures are required for PQRS):
- PQRS 126 — Diabetes Mellitus: Diabetic Foot and Ankle Care, Peripheral Neuropathy – Neurological Evaluation
- PQRS 127 — Diabetes Mellitus: Diabetic Foot and Ankle Care, Ulcer Prevention – Evaluation of Footwear
- PQRS 163 — Diabetes Mellitus: Foot Exam
For the new streamlined approach to work all 3 of the podiatry specific measures must be included in both the MU and the PQRS EHR-submission-method quality programs. Currently, just PQRS 163 is part of the PQRS EHR submission method, and therefore the only PQRS submission method that could work for DPMs is the tedious direct claim based method, or to pay a registry to submit provider claim-based data.
We have contacted the APMA, and it is our understanding that they will recommend to CMS that, by 2014 all 3 podiatry focused measures be included as part of the PQRS EHR submission method. This change to the EHR reporting method would place the Podiatric profession on equal footing with other specialties that will be leveraging CMS’s new vision for alignment of quality programs.
MediTouch EHR® is working hard with CMS to help your practice actualize this new unified quality reporting vision. We expect to become a certified PQRS EHR method submitter by the end of this year. In 2014 when reporting requires file submission for both the MU and PQRS programs, our users will have a simple method for meeting the requirements of both programs. We are monitoring how CMS implements their vision for program alignment, and working with stakeholders, such as the APMA, to make sure that none of our constituents are “left behind”.