MPFS: 2013 Changes to Physician Quality Programs

The Centers for Medicare & Medicaid Services’ (CMS’) Medicare Physician Fee Schedule (MPFS) proposed rule for 2013 foretells possible changes to several quality reporting initiatives, including the Electronic Prescribing (eRx) Incentive Program, the Physician Quality Reporting System (PQRS), and the PQRS-Medicare EHR Incentive Pilot.

Two new “hardship exemptions” to the eRx incentive program are proposed. From 2012 through 2014, the eRx program applies a negative payment adjustment for those eligible professionals (EPs) who are not successful electronic prescribers. CMS admits that physicians may have a hard time meeting both eRx and electronic health record (EHR) meaningful use requirements; therefore, in 2013 and 2014, CMS is proposing not to penalize EPs or group practices that do not meet eRx requirements—as long as they achieve meaningful EHR use.

CMS also proposes to exempt from eRx requirements EPs and groups that show intent to participate in an EHR incentive program. The EP or group would have to register for either the Medicare or Medicaid incentive program and would have to adopt certified EHR technology by a date that CMS will specify.

A revised PQRS program “includes simplified, lower burden options for reporting,” according to CMS. For 2013 and 2014, CMS proposes 264 individual measures and 26 measures groups that EPs can choose from, “including proposals to align the PQRS measures that would be available for EHR-based reporting with the measures available for reporting under the EHR Incentive Program,” a CMS Fact Sheet explains. CMS is proposing to expand the definition of “group practice” to include groups of  two to 24 EPs.

The agency also intends to post PQRS data supplied by group practices, and by accountable care organizations (ACOs) participating in the Medicare Shared Savings Program, beginning in 2014. Per the proposed rule, the minimum number of patients who must be included in each measure would be lowered to 20 (from the current 25). In the future, CMS wants to post patient experience data on physicians who participate in PQRS. Beginning in 2015, a payment adjustment applies to EPs who do not satisfactorily report data on quality measures for covered professional services.

The proposed rule also reiterates that EPs, eligible hospitals, and critical access hospitals (CAHs) that choose to participate in the Medicare and Medicaid EHR Incentive Programs must electronically submit clinical quality measure (CQM) results as calculated by certified EHR technology. CMS proposes to continue for 2013 the attestation method and the Physician Quality Reporting System-Medicare EHR Incentive Pilot for reporting CQMs that was established in the 2012 MPFS final rule.

The proposed rule will be published in the July 30 Federal Register. CMS will accept comments on the proposed rule until Sept. 4. A final rule with comment period will be issued by Nov. 1.

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