Value trumps volume in the evolving health-care system. In an effort to improve the quality of patient care, the Centers for Medicare and Medicaid Services (CMS) is strongly encouraging health-care providers to report quality measures on their patients. However, the complex reporting requirements of these programs can be daunting for psychologists.
CMS introduced the Physician Quality Reporting System (PQRS) in 2007 as an incentive- and penalty-based payment program in which eligible Medicare providers report data on quality measures for covered professional services provided to Medicare beneficiaries. The system includes measures aimed at promoting long-term health, such as preventive care and screening for clinical depression. Since 2007, the APA Practice Organization (APAPO) has been working to educate members about reporting program requirements. Psychologists who don't participate in 2014 by reporting PQRS measures for more than 50 percent of their applicable Medicare patients may face a 2 percent Medicare payment penalty in 2016.
To facilitate participation in PQRS, APAPO is exploring options to partner with a qualified registry for psychologists. A registry is an electronic system that allows eligible professionals to enter quality-measurement information for PQRS. The registry will collect clinical quality data, through a web-based program, spreadsheets and/or electronic health records. A registry would be responsible for calculating and submitting quality measures data to CMS in a specified format on behalf of the eligible professional or group practice for the respective program year. A list of registries qualified to submit PQRS data appears on the CMS website.
Although not used as often as claims-based reporting by mental health professionals, registries are an important option for psychologists to explore following the decision by CMS to make some measures ineligible for claims-based reporting in 2014 and beyond.
Two individual measures previously reported by psychologists through claims — No. 9 (Antidepressant Medication Management) and No. 173 (Unhealthy Alcohol Use Screening) — now must be reported through either a registry or electronic health records. In addition, all measures groups, including the dementia measures group, must now be reported via a registry. Measure No. 325, Adult Major Depressive Disorder, Coordination of Care of Patients with Specific Comorbid Conditions, has always been limited to registry reporting.
For 2014, registry and claims-based reporting have the same requirements: Providers must report nine measures across three domains for 50 percent of the eligible professional's applicable Medicare cases. Providers who report fewer than nine measures will have their data reviewed under the Measure Validation Process (MAV) to determine if additional measures could have been reported. If the MAV review indicates that the requirement to report nine measures across three domains requirement could not have been met, then the provider will not incur the 2 percent penalty in 2016.
Providers who use a registry can save time since they no longer need to manually add PQRS measures and codes to claims. In addition, they can submit the data as late as February of the following year. Registries automatically update the list of PQRS measures annually. Costs vary, but psychologists should expect to pay at least $250 annually to report through a registry. It is important to verify that a registry can support all of the measures on which a psychologist might report.
Resources for practitioners starting out in PQRS appear on APAPO's Practice Central website. They include:
- Updates to Medicare's Physician Quality Reporting System.
- Quick Reference Guide for PQRS Measures, Procedure Codes and G-codes.
- PQRS Measures for 2014.
- PQRS: Questions and Answers for Psychologists.
If you have questions about participating in PQRS, contact your local Medicare contractor or APAPO at (202) 336-5889 or email. APAPO will continue to monitor changing requirements and advise members of important information online and through our PracticeUpdate e-newsletter.
