Registries May Offer Advantages for PQRI Reporting
Look at your reporting options and find out how your EP can benefit most.
By Barbara J. Cobuzzi, MBA, CPC, CENTC, CPC-H, CPC-P, CPC-I, CHCC
Eligible physicians (EPs) who wish to participate in the Physician Quality Reporting Initiative (PQRI) may use one of three methods to report quality measures. They may report:
1. To the Centers for Medicare & Medicaid Services (CMS) on their Medicare Part B claims,
2. Through a qualified PQRI registry, or
3. To CMS via a qualified electronic health record (EHR) product.
Of these, the third option is the “easiest,” but works only if you already have a compliant EHR system up and running. As well, only a limited subset of measures may be reported via EHRs (10 in 2010, and up to 22 in 2011), leaving those EPs whose patient population isn’t described by the available measures subset out of luck.
EPs may pursue more than one reporting option during a reporting period, but of the remaining two options, certain EPs may find registry-based reporting offers important advantages over claims-based reporting. In my experience, using a registry is a piece of cake, and not at all as complicated as working with claims-based submissions.
For example, depending on the length of the reporting period the EP chooses (six or 12 months), registries offer more flexible (and potentially easier to achieve) reporting options. A well designed and supported registry also will alert you to potential reporting mistakes; whereas, claims-based reporting requires you to “get it right the first time” (claims may not be resubmitted for the sole purpose of correcting PQRI reporting errors). Finally, registry-based reporting may occur retroactively: For instance, measures for 2010 may be entered into the registry anytime up to Jan. 31, 2011. In contrast, claims-based PQRI reporting and submission of the actual claim must occur simultaneously.
Here’s the catch: Registry-based measures are different from claims-based measures, and apply to a narrower patient population. As such, not all EPs can take advantage of registry-based reporting.
Registry-based vs. Claims-based Reporting
Claims-based reporting encompasses 175 individual quality measures, plus four measures that together comprise the Back Pain measures group. The measures are weighted toward primary care, but an EP of almost any specialty will find several measures that may apply to his or her patient population.
Registry-based reporting, in contrast, relies entirely on measures groups, of which there are only 13 in 2010 (one measures group will be added for 2011). A measures group is four or more individual measures related to a clinical topic having a common patient population defined by diagnosis and/or encounter codes. In 2010, these measures groups are:
¦ Diabetes Mellitus
¦ Chronic Kidney Disease (CKD)
¦ Preventive Care
¦ Coronary Artery Bypass Graft (CABG)
¦ Rheumatoid Arthritis (RA)
¦ Perioperative Care
¦ Back Pain
¦ Hepatitis C
¦ Heart Failure (HF)
¦ Coronary Artery Disease (CAD)
¦ Ischemic Vascular Disease (IVD)
¦ Community-Acquired Pneumonia (CAP)
A complete list of measures groups, as well as qualifying CPT® patient encounter codes, ICD-9-CM codes, and measures group-specific intent HCPCS Level II G-codes may be found at: www.cms.gov/PQRI/15_MeasuresCodes.asp#TopOfPage. Select the link, “Getting Started with 2010 PQRI Reporting of Measures Groups,” near the bottom of the page.
These measures groups are skewed heavily in favor of primary care and cardiology, and EPs with these focus areas most easily would qualify for PQRI incentives under registry-based reporting. But an ear, nose, and throat specialist (ENT), to cite an example, likely would find that her patient population wouldn’t support registry-based reporting adequately—simply because the ENT would not be treating or tracking patients for the available measures groups.
To cite another example: The perioperative care measures group seems tailor-made for general surgeons but you must be careful. The measures group applies only to specific CPT® codes (as listed in the aforementioned Getting Started with 2010 PQRI Reporting of Measures Groups document). If the surgeon is not performing procedures reported using the applicable CPT® codes, the perioperative care measures group will not apply.
Ideally, in future years, CMS will increase the number of measures groups to apply more broadly across specialties, thereby making it easier for more EPs to participate in PQRI. For a fair system, every specialty should be able to use a registry.
Using a Registry
To become qualified, registries must meet certain technical and other requirements specified by CMS. A list of approved registries may be found on the CMS website www.cms.gov/PQRI/20_AlternativeReportingMechanisms.asp#TopOfPage: Select the “Qualified Registries for PQRI Reporting” link near the bottom of the page). Use only a CMS-approved registry. The registry will charge you a nominal fee per doctor to process and submit your information to CMS. For instance, the registry with which I am most familiar, PQRI Wizard, charges $299 per doctor, and will negotiate reductions in the per-doctor charge for groups of 10 or more physicians.
Note: I use PQRI Wizard in my examples because I have used this system most often to assist clients in submitting their PQRI data. Talk to your vendor: Any worthwhile registry should offer competitive pricing and functionality.
As an example of how a registry works, PQRI Wizard uses a questionnaire for each measure’s group that is available to their clients in Adobe PDF. The questionnaire mirrors the submission that you must complete when entering each patient. The specific CPT® and ICD-9-CM codes applicable to each measures group is listed on the questionnaire for that measures group. The system automatically tracks patients by reported CPT® codes, constantly updates your PQRI reporting status, and lets you know when you have collected sufficient data for submission.
For instance, under the group measures reporting guidelines (when submitting for a 12-month reporting period only), if the EP reports on all applicable measures within the selected measures group for a minimum sample of only 30 unique patients who meet patient sample criteria for the measures group, the EP is eligible for PQRI incentives (of the 30 unique patients, 28 may be non-Medicare Part B patients, ages 18 and above). A quality registry will monitor your progress to be sure you meet PQRI requirements (total number of patients and quality measures, etc.), and will alert you if there are missing or inconsistent data. This allows you to correct information so that information submitted to CMS is perfectly clean, thereby ensuring payment of your PQRI bonus.
For example, in one group that I worked with, there was a problem with the date the diagnosis first was made. PQRI Wizard contacted the client and asked them to go into the database and check the accuracy of the information. As such, both my client and the registry were making sure that the data submitted to CMS was appropriate, and a payable PQRI submission was made. Be sure your registry provides similar audits and feedback, so that you can enjoy the same successes.
Although registry-based PQRI reporting may apply more narrowly than claims-based reporting, it also may be applied with a greater level of success. The ease of using a registry, and the high rate of success and payment, suggest that if you can find a measures group that applies, registry-based PQRI reporting may be to your benefit. You will find the cost per physician is absorbed in labor savings, the Medicare incentive, and the knowledge that you will be successful.
Learn PQRI Basics
If you’re not already participating in PQRI, you probably should be. PQRI offers medical providers an opportunity to earn incentives of up to 2 percent of their total estimated Medicare Physician Fee Schedule-allowed charges for covered professional services within a reporting period. Although PQRI reporting is not mandatory, based on the trends we have seen with other CMS-sponsored programs (such as e-scribing and the adoption of EHRs), it’s safe to bet that providers who do not take part in PQRI will, at some time in the future, face reduced Medicare payments.
It’s now too late to participate in PQRI for 2010, but you shouldn’t lose your opportunity for 2011. Information for PQRI eligibility may be found on the CMS website. From this site, you can view a list of applicable quality measures, a list of frequently-asked questions, and additional information to help you get started with the program.
EPs are not just physicians (e.g., doctors of optometry and chiropractic), but also mid-level providers such as physician assistants (PAs), clinical psychologists, and more, as well as physical and occupational therapists (PTs and OTs). Individual EPs do not need to sign up or preregister to participate in the PQRI. Program requirements and measure specifications differ from year to year, and EPs are responsible for ensuring they use the PQRI documents for the correct program year.