UPFRONT

Alphabet Soup

Peter K. Kaiser, MD

On March 23, 2010, President Obama signed the ACA into law. When the Supreme Court upheld the law in 2012, our pain with this poorly conceived alphabet soup started. Failing to understand these letters will cost you money.

In 2007, CMS created PQRS. When it started, to avoid a penalty, EPs were only required to report on three measures, and reporting on a single patient was sufficient to avoid a penalty. After MACRA section 102, CMS was required to post a Quality MDP to support MIPS and APMs.

The result is that in 2017 you need to choose at least nine individual measures across three or more different NQS domains and at least one cross-cutting measure to satisfy PQRS and avoid a penalty. If you submit fewer than nine measures, CMS uses a MAV process to determine whether an EP should have reported additional measures. The NQS was mandated by ACA and published in 2011.

Each measure can require 10 to 20 yes-or-no answers. Answering in a paper chart is essentially impossible, which is the whole idea. The use of EMR is required, and it is imperative to ensure the one you have can handle this reporting.

Failure to report PQRS measures in 2015 carries significant penalties — up to a 2% penalty on all Medicare Part B and Medicare Payments in 2017. If you are in a large group, there could be an increase in penalties of another 2% for groups with one to nine providers and 4% for groups with more than 10.

To make our lives easier, retina received two new PQRS measures: #384 = % of surgeries for primary RRD repairs that were attached with one surgery; and #385 = % of RRD cases attached six months after surgery.

However, CMS has not discussed what a good measure of quality is for these measures. And by the way, NQS will publicly report EP performance on these measures to plans, providers, patients, and accreditation organizations. My guess is PR will decrease, and primary PPV will increase to improve success rates for #384.

Are you ready to report your PQRS with your EMR, or are you using IRIS? Will you avoid a penalty in 2017, or are you SOL? In this issue, we give you valuable advice about using this registry and ways it is used by several prominent retina practices.

Alphabet Soup Glossary:

ACA = Affordable Care Act

APM = Advanced Payment Models

CHIP = Children’s Health Insurance Program

EP = Eligible professional

MACRA = Medicare Access and CHIP Reauthorization Act of 2015

MAV = Measure-Applicability Validation

MDP = Measure Development Plan

MIPS = Merit Based Incentive Payments System

NQS = National Quality Strategy

PQRS = Physician Quality Reporting System

PR = Pneumatic retinopexy

RRD = Rhegmatogenous retinal detachment

SOL = Sh*t out of luck

VBPM = Value Based Payment Modifier