PQRS: Looking Back
Last week I had the pleasure of joining several colleagues in the CMS 2012 PQRS kick-off meetings. 2012 marks the 4th year Acumen will participate as a CMS qualified registry. I thought this might be a good time to look back over the PQRS experience as history frequently informs the future. CMS makes this easy for us as they recently published a summary of their experience through 2010. Let’s take a look.
The PQRS program began in 2007 as a claims-only process over the second half of that year. Registry reporting and the reporting of measures groups followed in 2008. Reporting options have literally exploded in the interim as the following graphic from the report describes.
Numbers of Measures in the Physician Quality Reporting System by Reporting Option (2009 to 2011).
This trend continues in 2012 as there are now 210 individual measures and 22 measure groups available for reporting.
Registry Reporting on the Rise
During the program’s first year, reporting was restricted to submitting a quality data code (QDC) with the claim for the Medicare Part B beneficiary. Registry reporting was introduced as an alternative reporting method in 2008. Over the past few years registry reporting has exploded in popularity among eligible professionals. This is also true for nephrologists as is depicted in the following graphic I have abstracted from the CMS report referenced above.
Nephrologist Participation: Rise of Registry Reporting
IM and MG in the graphic above refer to “individual measures” and “measures groups” respectively. Note the absence of growth in the number of nephrologists reporting PQRS via claims compared with substantial growth in registry reporting. The popularity of registry reporting is related to several factors, not the least of which is the success rate associated with registry reporting which is depicted in the graphic below. This, in large part, is related to the opportunity to report retrospectively as opposed to being required to submit QDCs with the claim on the date of service.
Nephrology Success Rates
As the graphic depicts, nephrologists reporting PQRS via a registry are successful over 90% of the time compared with claims-based reporting of PQRS where the success rate is closer to 50%.
Impact on Nephrology
CMS has not published their 2011 results as the registry reporting window only recently closed. Of interest, almost 2,400 nephrologists submitted PQRS data to CMS in 2010. That year was the first year more nephrologists reported via a registry than via claims, reflecting the rising popularity of the registry reporting method. Almost 1,900 nephrologist or 79% of those submitting data were successful in 2010. As you may recall, the incentive in 2010 was 2.0% of the provider’s Medicare Part B allowable for the calendar year. CMS paid these 1,900 nephrologists an average of $6,300 for their successful participation in the program.
The incentive dropped to 1.0% last year, and drops further to 0.5% of the Part B allowable in 2012. One might anticipate this will result in a drop-off in demand for PQRS reporting in 2012. I think that is likely to be the case. However, PQRS reporting is likely to increase again in 2013, which is the first PQRS adjustment payment-reporting period. Not reporting PQRS in 2013 will result in the provider sustaining a 1.5% reduction in their Medicare Physician Fee Schedule in 2015. If this sounds familiar, it should, as it is identical to the method employed by the eRx program, which is in play today. I plan to address this aspect of the PQRS program in a future post.
Have you participated in PQRS? Join the conversation and let us know what you think about the program.