One could use the claim reporting method. However:
There are many advantages to submitting your PQRS data via a qualified CMS registry. These include:
MDinteractive supports all 2016 PQRS registry-based individual measures and measures groups.
Currently, customer support (via 1-800-634-4731 or online chat) is available from 9-5 EST on Monday-Friday. As we move closer to the PQRS deadline (February 15, 2017), customer support hours will be expanded. Hours will be updated on our website.
All providers must sign a consent giving MDinteractive permission to submit their data to CMS. Consents signed by a provider from previous PQRS submissions are still valid.
When doing the EHR MU Attestation and reporting PQRS using MDinteractive please choose option 2 (I will submit my clinical quality measure data right now through attestation) because a provider using MDinteractive Qualified PQRS registry or the MDinteractive Specialized registry will NOT satisfy the eCQM EHR MU reporting requirement.
Yes. CMS will make their payment adjustment based on the most complete set of data received. The two methods cannot be combined however.
A Measures Group is the easiest way to report and only requires a 20 patient sample - 11 of which must be traditional Medicare Part B FFS. Not all specialties/providers will find Measures Groups that “work” for them. In these instances, a provider can look to report 9 individual measures across 3 NQS domains, including 1 cross-cutting measure. When reporting an individual measures, the provider would include at least 50% of the traditional Medicare patients meeting the eligibility of that particular measure. Only Medicare patients are included in this type of reporting.
No! The 20 patient sample applies only to reporting via Measures Groups. If reporting using an individual measure (or clusters of individual measures), a provider must report on at least 50% of all Medicare FFS patients who meet the eligibility of that measure.
Yes. When creating patient records for any individual measure, you must enter at least 50% of the provider’s traditional Medicare patients that meet the eligibility of that particular measure.
Non-Medicare patients can only be used for PQRS reporting if you are reporting using a Measures Group. In this instance, CMS allows less than 50% (or 9 of the 20) to be other types of insurance. 11 must be one of the following: Medicare Part B primary, secondary, Railroad or CAH method II. When reporting individual measures, only Medicare Part B patients are included in the reporting.
PQRS reporting of individual measures applies only to patients with Medicare Part B (primary, secondary, Railroad Retirement Board and CAH method II). It is not applicable to Medicare Advantage or Medicaid.
A cluster is a collection of clinically related measures. A provider will avoid the PQRS penalty if he or she reports all of his or her Medicare patients for all of the measures contained within a cluster. The link for 2016 clusters and how it relates to the MAV can be found here: MAV.
MAV is the Measures Applicability Validation process. A clinical relation/domain test is applied when a provider submits less than 9 measures across 3 NQS domains or 9 measures across less than 3 domains. The MAV is used to determine whether or not a provider could have reported additional measures. When successfully reporting using a “cluster” of clinically related measures and a cross-cutting measure, a provider should pass the MAV.
If you take a look at your claim forms you will see that there are two different spots for NPIs. The 33a field is where the Group NPI is listed. Please do not report PQRS using the Group NPI.
The 24J field should contain the individual NPI. The TIN in field 25 and the individual NPI listed in 24J should always be used to report PQRS.
Start by reviewing the suggestions by specialty available on our website: http://www.mdinteractive.com/2016-pqrs-specialty
The measures you select should reflect your patient population, specialty and practice.
"n/a" indicates that you had no patients eligible for the measure. For example, you will get that result on the mammography, urinary incontinence and osteoporosis screening questions for the preventive care measures group if your patient sample only included males. It is an acceptable value and will not negatively impact your PQRS submission results.
Providers must report one cross-cutting measure if they have at least one face-to-face encounter (based on patient encounter codes) with a Medicare patient. A cross-cutting measure would be in addition to a cluster of clinically related measures or as part of 9 Individual Measures across three NQS domains. Providers reporting using Measures Groups do not have to include a cross cutting measure in addition. A list of the broadly applicable cross cutting measures can be found here: cross-cutting measure.
Please reference the 2016 PQRS List of Face-To-Face Encounter Codes for the billable codes that identify face-to-face encounters for the purposes of 2015 PQRS reporting. This list includes general office visits, outpatient visits, and surgical procedure codes.
Please note that cross-cutting measures apply in general to many Medicare patients. For example if you have 100 Medicare patients, you would expect to report cross-cutting measure #226 Tobacco Use: Screening and Cessation Intervention on at least 50 Medicare patients (50% reporting rate).
There are however some cross-cutting measures that apply to smaller patient populations:
Reporting less than 9 measures (or fewer than 3 domains) is subject to the Measures Applicability Validation Process or MAV. CMS applies a "clinical relation/domain test" to determine whether additional measures could have been reported. If all of the measures within a cluster have been successfully reported by a provider, he or she will pass the MAV and avoid the PQRS penalty.
The reporting rate is the percentage of times that you answered all of the questions related to a particular measure. For Measures Groups, all of your reporting rates must be 100%. In other words, you cannot leave a question unanswered or blank. For individual measures, your reporting rates must be at least 50% meaning you answered the quality questions on 50% or greater of the patient records created.
The performance rate is the percentage of times you met the measure (answered "done" or "performed") compared to the number of eligible patients entered for the measure. Performance rates - with the exception of inverse measures where the lower percentage is better (100%) would not be acceptable in this instance - must always be greater than 0%.
MDinteractive provides CMS with the reporting and performance rate calculations for the measures submitted by a provider (using the combination of the individual NPI/TIN as the identifier). Individual patient information is not submitted to CMS.
For individual measures, EPs must report eligible Medicare patient visits for the entire 12 month period - January 1, 2016-December 31, 2016. When reporting using Measures Groups, the 20 patient visits (11 of which must be Medicare) must be within the reporting period.
Yes. Our site has been updated for 2016 and you may begin creating patient records. If you do not see a particular measure in your drop-down menu, please contact us via either our 800# (1-800-634-4731), e-mail (firstname.lastname@example.org) or chat on our website.
You can begin entering data from the beginning of the year to the present and then continue to add patients until December 31, 2016. For individual measures, it is suggested that you start entering the data as early in the year as possible.
Measures groups can be completed at any time during the year.
All data must be submitted to MDinteractive by February 15, 2017.
PQRS Feedback Reports webpage:
A few comments:
1 - All 2015 PQRS reports and QRURs with value modifier information will be found here:
2 - If a provider thinks they are getting a penalty, please forward us the PQRS feedback report and the Supplementary Exhibit 11. Individual Eligible Performance on the 2015 PQRS Measures.
3- Providers can potentially have PQRS and/or Value Modifier penalties. Please note that the appeals webpages are different for each one of these programs.
CMS typically releases information regarding your submission in the form of a PQRS feedback report in the 4th quarter (early Fall) of the following year. When these reports become available, you can contact the QualityNet Help Desk to access your feedback report.
The deadline for submitting data into our registry for 2016 reporting is February 15, 2017.
The CMS portal to send PQRS data opens in January 2017. We will begin sending complete data that has been reviewed by our team beginning in January 2017 and continue through March 2017.
The Value-Based Modifier will apply to all physicians in 2018. Non-reporting (of PQRS) in 2016 will automatically result in a -2% VM payment adjustment for groups of 1-9 providers and a -4% adjustment for groups of 10 or more. This is in addition to the -2% PQRS penalty for not reporting.
The VBM payment adjustment is applied through quality-tiering. Quality-tiering is the methodology used to evaluate a group or solo practitioner’s performance on quality and cost measures for the Value Modifier. PQRS quality data and Medicare cost data is used to determine a provider's (or group of providers) overall score. This system rewards high performance with increased payments and reduces payments to lower scorers.
Groups with 10 or more EPs could receive an upward adjustment (up to 4x the adjustment factor), a (up to 4%) downward adjustment, or no adjustment . 1-9 EPs could receive an upward adjustment (up to 2x the adjustment factor) or no adjustment.
GPRO is the Group Practice Reporting Option. GPRO is open to practices of 2 or more providers operating under a single TIN. If at least one provider in the group has eligible patient visits to report, every member of the group will avoid the PQRS penalty. CMS registration for GPRO is required prior to June 30, 2016. MDinteractive does support GPRO PQRS submissions. We ask that you contact us via e-mail (email@example.com) if you will be submitting via GPRO. The cost for GPRO is $199 per provider that submits PQRS measures.
A practice must register directly with CMS for GPRO. It is open to all practices with 2 or more providers. The registration period for GPRO through the CMS web portal is between April 1, 2016 and June 30, 2016. Once you have registered as GPRO with CMS, we ask that you send us an e-mail (firstname.lastname@example.org) with confirmation of your GPRO registration.
Non-patient facing MIPS eligible clinicians will have their ACI category automatically reweighted to zero by CMS.
"We proposed to automatically reweight the advancing care information performance category to zero for a MIPS eligible clinician who is classified as a non-patient facing MIPS eligible clinician (based on the number of patient-facing encounters billed during a performance period) without requiring an application to be submitted by the MIPS eligible clinician."
"Under the MIPS, we proposed to automatically reweight the advancing care information performance category to zero for any hospital-based MIPS eligible clinicians and/or nonpatient facing MIPS eligible clinicians who may not have sufficient measures applicable and available to them."
Hospital-based MIPS eligible clinicians will have the ACI category automatically weighted to zero by CMS. Hospital-based ECs are those who provide 75 percent or more covered professional services in the inpatient hospital (POS 21), on campus outpatient hospital (POS 22) or emergency room (POS 23) settings.
"For these reasons, we proposed to rely on section 1848(q)(5)(F) of the Act to assign a weight of zero to the advancing care information performance category for hospital-based MIPS eligible clinicians."
"With consideration of the comments and data we have reviewed, we are reducing the percentage of covered professional services furnished in certain sites of service to determine hospital-based MIPS eligible clinicians from 90 percent to 75 percent. The data analyzed supports the comments we received while still allowing MIPS eligible clinicians with 25 percent or more of their services in a settings outside of inpatient hospital, on-campus outpatient hospital (as referenced below) or emergency room settings to participate and earn points in the advancing care information performance category."
"We agree with commenters that there are MIPS eligible clinicians who bill using place of service codes other than POS 21 and POS 23 but who predominantly furnish covered professional services in a hospital setting and have no control over EHR technology. We believe these clinicians should be considered hospital-based for purposes of MIPS, and therefore, we are expanding our hospital-based definition to include POS 22, on-campus outpatient hospital."
"We noted that the Medicaid EHR Incentive Program for EPs was not impacted by the MACRA and the requirement under section 1848(q) of the Act to establish the MIPS program. We did not propose any changes to the objectives and measures previously established in rulemaking for the Medicaid EHR Incentive Program, and thus, EPs participating in that program must continue to report on the objectives and measures under the guidelines and regulations of that program. Accordingly, reporting on the measures specified for the advancing care information performance category under MIPS cannot be used as a demonstration of meaningful use for the Medicaid EHR Incentive Programs. Similarly, a demonstration of meaningful use in the Medicaid EHR Incentive Programs cannot be used for purposes of reporting under MIPS. Therefore, MIPS eligible clinicians who are also participating in the Medicaid EHR Incentive Programs must report their data for the advancing care information performance category through the submission methods established for MIPS in order to earn a score for the advancing care information performance category under MIPS and must separately demonstrate meaningful use in their state’s Medicaid EHR Incentive Program in order to earn a Medicaid incentive payment. The Medicaid EHR Incentive Program continues through payment year 2021, with 2016 being the final year an EP can begin receiving incentive payments (§ 495.310(a)(1)(iii)).
We solicited comments on alternative reporting or proxies for EPs who provide services to both Medicaid and Medicare patients and are eligible for both MIPS and the Medicaid EHR Incentive Payment. The following is a summary of the comments we received regarding our proposal to separate the reporting requirements of MIPS and the Medicaid EHR Incentive Programs:
Comment: Many commenters stated the reporting burden imposed on MIPS eligible clinicians who also participate in the Medicaid EHR Incentive Programs, would have to report separately to achieve points in the advancing care information performance category, and to receive an incentive payment in the Medicaid EHR Incentive Programs. Some commenters urged CMS to align reporting requirements and submission methods across both programs to eliminate duplication in reporting effort. Some commenters requested that CMS eliminate the need to report duplicative quality measures by modifying its proposal to require that if quality is reported in a manner acceptable under MIPS or an APM, then it would not need to be reported under the Medicaid EHR Incentive Program. Other commenters expressed concern that varying reporting requirements for MIPS eligible clinicians, for hospitals and Medicaid EPs who participate in the EHR Incentive Programs will bring hardship to clinician staff, as well as EHR vendors.
Response: We understand that reporting burden is a concern to MIPS eligible clinicians and CMS remains committed to exploring opportunities for alignment when possible. However, MIPS and the Medicare and Medicaid EHR Incentive Program are two separate programs with distinct requirements. The reporting requirements and scoring methods of the Medicaid EHR Incentive Program and those finalized for the advancing care information performance category in the MIPS program differ significantly. For example, in the Medicaid EHR Incentive Programs, EPs must report on all objectives and meet measure thresholds finalized in the 2015 EHR Incentive Programs final rule. In the advancing care information performance category, MIPS eligible clinicians must report on objectives and measures, but are not required to meet measure thresholds to be considered a meaningful EHR user. We remind commenters that while MIPS eligible clinicians would be required to meet the requirements of the advancing care information performance category to earn points toward their MIPS final score, there is no longer a requirement that EPs demonstrate meaningful use under the Medicaid EHR incentive program as a way to avoid the Medicare EHR payment adjustments. However, MIPS eligible clinicians who meet the Medicaid EHR Incentive Program eligibility requirements are encouraged to additionally participate in the Medicaid EHR Incentive Program to be eligible for Medicaid incentive payments through program year 2021.
Comment: A few commenters proposed that MIPS eligible clinicians who are participating in the Medicaid EHR Incentive Program be exempted from reporting to MIPS until after the completion of their final EHR performance period. Others proposed allowing clinicians to choose either to report in the Medicaid EHR Incentive Program or the advancing care information performance category of MIPS. One commenter suggested awarding MIPS eligible clinicians 30 points toward the advancing care information performance category score if they successfully attest to meaningful use in the Medicaid EHR Incentive Program.
Response: As previously mentioned, objective and measure requirements of the Medicaid EHR Incentive Program and those finalized for the advancing care information performance category in the MIPS program vary too greatly to enable one to serve as proxy for another. We are finalizing our Medicaid policy as proposed."
"Comment: Some commenters requested that CMS clarify the proposal to eliminate the need to track and report duplicative quality measures by modifying its proposal to require that if quality is reported in a manner acceptable under MIPS or an APM, it would not need to be reported under the Medicaid EHR Incentive Program. The commenters were concerned the programs could potentially cause the same conflict CMS specifically noted MIPS and APMs were intended to correct.
CMS Response: We thank the commenters and have worked to eliminate duplicative measures between MIPS and other programs where possible. We intend to continue to align MIPS and the Medicaid EHR Incentive Program to the greatest extent possible. As we have noted in section II.E.5.g. of this final rule with comment period, the requirements for the Medicaid EHR Incentive Program for EPs were not impacted by the MACRA. There is a requirement to submit CQMs to the state as part of a successful attestation for the Medicaid EHR Incentive Program. While the MIPS objectives for the advancing care information performance category are aligned to some extent with the Stage 3 objectives in the Medicaid EHR Incentive Program, they are two distinct programs, and reporting will stay separate.
"In addition, we recognize that under MIPS, there will be more eligible clinicians subject to the requirements of EHR reporting than were previously eligible under the Medicare and/or Medicaid EHR Incentive Program, including hospital-based MIPS eligible clinicians, nurse practitioners, physician assistants, clinical nurse specialists, and certified registered nurse anesthetists. Since many of these non-physician clinicians are not eligible to participate in the Medicare and/or Medicaid EHR Incentive Program, we have little evidence as to whether there are sufficient measures applicable and available to these types of MIPS eligible clinicians under our proposals for the advancing care information performance category. As a result, we have provided additional flexibilities to mitigate negative adjustments for the first performance year (CY 2017) in order to allow hospital-based MIPS eligible clinicians, nurse practitioners, physician assistants, clinical nurse specialists, certified registered nurse anesthetists, and other MIPS eligible clinicians to familiarize themselves with the MIPS program. Section II.E.5.g.(8) of this final rule with comment period describes our final policies regarding the re-weighting of the advancing care information performance category within the final score, in which we would assign a weight of zero when there are not sufficient measures applicable and available."