Deadline Reminder: Preparing to Submit Your PQRS Measures
by Thomas E. Serena MD, FACS, FACHM, FAPWCA
An ancient Irish tradition dating back to St. Patrick permitted women to propose marriage to men on the additional day added during a leap year. The gender equality of modern society has turned this tradition into mere folklore, but it is hardly cause for concern here in Boston as we have no shortage of Irish traditions.
PQRS Measures Submission Preparedness
2016 is a leap year as are most years divisible by four. I am not anticipating any offers of marriage this year. However, this February 29th has acquired an ominous association: a connotation on the scale of April 15th or October 29th (stock market crash of 1929). This year, February 29th is the last day for physicians to submit Physician Quality Reporting System (PQRS) quality measures to the Centers for Medicare and Medicaid Services (CMS) either directly or through an accredited registry. Failure to comply will result in a financial penalty.
We are Americans: It is our tradition to wait until the last minute in all situations bureaucratic; and physicians are perhaps the most notorious procrastinators of all. We, at SerenaGroup, have been working on the PQRS for a year. We have already collected the required information in our database and in the proper format. Admittedly, we are rushing about with some last minute preparations, but we will be ready to meet the CMS deadlines.
On the other hand, there is hope for the under-prepared. There is still time, if you sharpen your pencils and dig into your health record. Your stress level will depend largely on the ease of accessing the required information. What if you miss the deadline? Fortunately, if you are already using an electronic health record platform with meaningful use status, the penalties this year will only add up to about a 4% or 5% reduction in Medicare payments. More importantly, it is time to prepare for next year now.
Wound Care and Accredited Registry Reporting
The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) developed a new physician payment called MIPS, the Merit-Based Incentive Payment System. It is a combination of PQRS quality measures, the Value-based Payment Modifier (VBM), and the Medicare Electronic Health Record (EHR) incentive program. Failure to pass under the MIPS system will convert your 2016 Medicare patients into no-pay patients.
For woundologists, there is an additional caveat: it is not as simple as reporting PQRS measures. It is essential that you report measures that are specific to the practice of wound care. Unfortunately, the current published PQRS measures fall short in this regard. As a result, wound care practitioners can either report barely relevant PQRS measures or report quality measures pertinent to their practice through an accredited registry. Reporting only PQRS measures may be adequate for this year but it is not advisable in the future.
Why is the registry reporting important to wound care practitioners? Isn't this just more meaningless government paperwork? The answer is 'No!' CMS plans on publishing your MIPS score (0-100) and quality measure performance for all to see. Physicians will be compared to each other based on the quality measures they submit. You could easily be the best woundologist in America but if you choose to report PQRS measures that do not reflect your skill in wound care, you could end up with a disappointing MIPS score. Moreover, the MIPS score could be used for any number of purposes: qualifying practitioners for commercial insurance panels, maintaining hospital privileges or board certification and naturally by competitors to gain advantage.
Physicians can hope for the luck of the Irish, but I advise a well-planned quality reporting strategy that includes accredited registry reporting and thinking ahead to the year to come.
About The Author
Dr. Thomas Serena has published more than 75 peer-reviewed papers and has made in excess of 200 presentations worldwide. He has been elected to the Board of Directors of both The Wound Healing Society and the American College of Hyperbaric Medicine (ACHM), the leading academic society in the field of Hyperbaric Medicine. In 2014 Dr. Serena was elected president of the American Professional Wound Care Association (APWCA). Dr. Serena has opened and operates Wound Care and hyperbaric oxygen treatment clinics across the United States.
The views and opinions expressed in this blog are solely those of the author, and do not represent the views of WoundSource, Kestrel Health Information, Inc., its affiliates, or subsidiary companies.