On Wednesday, November 27, the Centers for Medicare and Medicaid
Services (CMS) released its 2014 Physician Fee Schedule (PFS) Final Rule for
calendar year 2014. In addition to payment policies, the rule outlines
changes in the Physician Quality Reporting System (PQRS), the Medicare
Electronic Health Record (EHR) Incentive Program, and the Physician Compare
website. The implementation of the Value-Based
Payment Modifier Program (VBMP) is also discussed. CMS will accept comments on
the Final Rule through January 27, 2014.
ISIS is reviewing the document and will be developing comments to submit
to CMS in the coming weeks. Brief
descriptions and some highlights of changes made to these programs are included
PQRS: The PQRS is a quality reporting
program that has been using incentive payments to encourage eligible
professionals (EPs) to report on specific quality measures to both ensure that
patients receive the proper care at the proper time and quantify how often the
providers meet a particular quality metric.
Providers can report via Medicare Part B claims, a physician quality reporting
registry, a qualified EHR product, or a qualified data submission vendor. With feedback reports provided by CMS, EPs may compare their performance with
their peers. In 2015, PQRS will begin to
use payment adjustments to further encourage reporting.
Incentive Payments and Payment
Adjustments: Individual EPs who meet the criteria for
satisfactory submission of PQRS quality measures data via one of the accepted
reporting mechanisms for services furnished during the 2013 and 2014 reporting
periods will qualify to earn an incentive payment equal to 0.5% of their total
estimated Medicare Part B PFS allowed charges for covered professional services
furnished during that same reporting period. Beginning in 2015, the program
applies a -1.5% payment adjustment to EPs who did not satisfactorily report data
on quality measures for covered professional services during the 2013 PQRS
program year. The negative payment
adjustment will increase to 2% in 2016 for EPs who do not satisfactorily report
in the 2014 PQRS program year.
to Measures and Reporting Criteria of Interest to ISIS Members:
- Across the claims, registry, and EHR
reporting methods, the new requirements to achieve the
"satisfactorily reporting" incentive are: 9 measures across 3
National Quality Strategy domains. The goal of these requirements is
to allow eligible professionals to avoid the payment adjustment described
- The Back Pain Measures Group will be
reportable via Registry only.
- Two New PQRS Reporting Options:
- Certified Survey Vendors will be
available to group practices of 25 or more EPs which participate under
the Group Practice Reporting Option (GPRO), and which agree to report
Clinician and Group Consumer Assessment of Healthcare Providers and
Systems (CG-CAHPS) data. The data collected will be submitted by the
vendor and the results eventually will be posted on the Physician Compare
- Qualified Clinical Data Registries (QCDR)
are CMS-approved entities that have self-nominated and completed a
qualification process to serve as QCDRs and meet certain data and program
requirements. The deadline for a QCDR to self-nominate is January
31, 2014 with a March 31 deadline to submit measures information.
Medicare EHR Incentive Program: This program provides incentive
payments to eligible professionals and facilities as they implement certified
electronic health record technology and demonstrate meaningful use of the EHR. The incentive payment is 75% of a provider’s
Medicare allowed charges, up to $44,000 over five consecutive years, and there
is an additional incentive for those who practice in a Health Professional
Shortage Area. EPs must begin their EHR
process by 2014 to receive EHR incentive payments; the final incentive payment
year is 2016. In 2015, payment
adjustments of 1% per year will begin for providers who are eligible for the
Medicare EHR Incentive Program but decided not to participate; depending on the
total number of Medicare EPs who participate after 2018, the maximum cumulative
negative payment adjustment is 5%. Meaningful
use of the EHR technology must be demonstrated in order to receive the
incentive. Specific requirements
relative to the reporting methods and reporting periods of Clinical Quality
Measures (CQM) are outlined in the final rule.
Physician Compare website: The Physician Compare
website allows consumers to search for physicians and other healthcare
professionals who provide Medicare services. At this time, the site provides
information on providers’ names, addresses, contact information, specialties,
clinical training, gender, languages spoken, affiliated hospitals, and Medicare
payment information for both individual practitioners and group practices. Physician Compare includes information from
providers who satisfactorily participate in CMS quality programs, including
PQRS, the eRx Incentive Program, the EHR Incentive Program, the Medicare Shared
Savings Program, and the Value-based Payment Modifier. A full redesign of the website was launched in
2013 to implement improvements to the underlying database as well as an
Intelligent Search feature; the changes addressed improving functionality and
usability of the website for consumers.
- The first set of measure data will be
posted on Physician Compare in early 2014, reflecting data
collected no earlier than program year 2012 from the PQRS GPRO measures
for groups of all sizes.
- It is anticipated that only data collected
in 2013 under the GPRO Diabetes Mellitus (DM) and Coronary Artery Disease
(CAD) measures and composites will be publicly reported in late 2014.
- 2014 data will be publicly reported in
2015, on all measures collected through GPRO for groups of all sizes;
providers will have a 30-day preview period of their data.CMS states
that a detailed timeline for the preview will be provided in advance of
- A quality programs section has been added
to each group practice profile page to indicate satisfactory reporting in
the GPRO or e-prescribing under the eRx Incentive Program.
- PQRS individual measure data collected in
2014 will be publicly reported in 2015 for individual PQRS quality
measures, if technically feasible. The individual PQRS quality measures
will be in line with those measures reported by groups in GPRO.
Value-Based Payment Modifier Program (VBPM): The VBPM Program will provide comparative performance
information to physicians as part of Medicare's efforts to improve the quality
and efficiency of medical care. By providing meaningful and actionable
information to physicians so they can improve the care they deliver, CMS is
moving toward physician reimbursement that rewards value rather than volume.
Currently the program applies only to physicians in large groups, but by 2017
all physicians who participate in Medicare FFS will be affected by the value
- In 2015, physicians of groups of 100 or more EPs who submit claims
to Medicare will be subject to the VBPM, based on their calendar year 2013
performance. Groups that fail to report will be subject to a -1% value
modifier adjustment to their 2015 payment.
- The VBPM adjustment is in addition to the PQRS payment adjustment.
will accept comments on the Final Rule through January 27, 2014. ISIS is reviewing
the document and will be developing comments to submit to CMS in the coming
entire rule can be found at: http://www.ofr.gov/OFRUpload/OFRData/2013-28696_PI.pdf