Surviving PQRS 2016 Radiologist Edition
Summer 2016 is here, and many providers are preparing for their Physician Quality Reporting System (PQRS) participation. With penalties associated with PQRS and the Value Based Modifier program (VM) standing between 2-6% of Medicare payments, and administrative requirements on the rise, there’s a heightened concern associated with deadline readiness (The first deadline being 2/24/17 for claims-based reporting). However, there are several changes and additions specific to the radiology field that will allow for more reporting choices, and subsequently, a higher probability of successful submission to avoid penalties. Let’s uncover tips and the steps necessary to help your organization be ready for deadline.
1. Know The Basics - What is PQRS and VM?
The Physician Quality Reporting System (PQRS) is a voluntary quality reporting program that encourages professionals to confirm that specific services were rendered when predetermined criteria were met. In addition, it gives organizations the opportunity to realize opportunities for improvement. The Value-Based Modifier (VM) works in conjunction with a physician’s PQRS data to allow Medicare to apply an additional adjustment (which can be positive, neutral, or negative) to a physician’s payments under the Medicare Physician Fee Schedule based upon the quality and cost of care.
2. Know the Penalties
Since VM payments are more subjective in comparison, the distribution of these payments and penalties are dependent on PQRS participation and quality/cost reporting of other physicians. If an eligible professional fails to successfully participate in PQRS in 2016, 2018 Medicare reimbursements are reduced by 2%.
So, how do you avoid penalties? Each radiologist must report on 9 PQRS measures covering at least 3 NQS domains and then report the PQRS codes on at least 50% of eligible patients. One of the measures must be a cross-cutting measure if the provider bills for face-to-face encounters. If fewer than 9 measures apply, the eligible professional must report on all applicable measures.
For reference, the NQS domains are as follows:
- Effective Clinical Care
- Patient Safety
- Care Coordination
- Person and Care Giver-Experience and Outcomes
- Efficiency and Cost Reduction
- Community/Population Health
If you're unable to report on a sufficient number of measures, know that the Measure-Applicability Validation (MAV) process is another option - which may be beneficial to small radiology groups where radiologists operate as subspecialists (if you concentrate on a narrow range of patients) – but MAV process administrators must agree that there were indeed not enough cases to report nine measures across three domains.
3. Know Your Options for Participation
Claim-based reporting has continued to be the best choice for radiologist groups. If you’re uncomfortable with this option, Individual PQRS Registry Reporting is another safe option. Here is a full list of reporting options:
- Individual claims-based reporting*
- Individual PQRS registry reporting*
- Qualified Clinical Data Registries (QCDR) – radiologists can use this option via the QCDR offered by The American College of Radiology
- A qualified Electronic Health Records (EHR) product
- Group Practice Reporting option
- PQRS measures groups
- Accountable Care Organizations (ACOs)
4. Know Which Claims-Based Measures To Focus On (Radiology Specific)
Obviously, choose PQRS measures that are specific to your practice and performed frequently. But consider this – how long will it take to document those requirements? With that in mind, there are specific measures that are popular amongst radiologists according to ease of documentation and success rates. RBMA has provided a list of the most popular according to their coding forum. The best PQRS radiology measures are as follows, with noted measures that are new to 2016.
- 21 – Use of prophylactic antibiotics in various surgical procedures
- 22 – Discontinuation of prophylactic antibiotics
- 23 – Venous thromboembolism prophylaxis
- 24 – Osteoporosis communication in men/women 50+ (revised)
- 76 – CVC insertion
- 145 – Fluoroscopy
- 146 – Screening mammography
- 147 – Bone nuclear medicine
- 195 – Carotid imaging
- 225 – Screening mammogram reminders
- 405 – Abdominal lesion follow up (new)
- 406 – Thyroid nodule follow up (new)
- 418 – Osteoporosis management in women who’ve had a fracture (new)
- 436 – Utilization of CT dose lowering techniques (new)
- 437 – Surgical conversion for endovascular revascularization procedures
*In addition, know that you must provide additional information for Individual Registry Reporting
Similar to claims-based reporting, professionals must report on 9 PQRS measures across 3 NQS domains and must be applied to at least 50% of the applicable studies for Medicare patients. The same radiology-specific measures that can be reported for claims-based can also be reported for individual registry. In addition, individuals must include additional documentation elements in their report which must be submitted (by your organization OR your billing company) all at once to a Certified PQRS registry by the end of the 2016 calendar year and before March 31st of 2017. There are 12 specific PQRS measures that are REGISTRY ONLY related to radiology:
- 259 – Rate of endovascular aneurysm repair of small or moderate non-ruptured abdominal aortic aneurysms without major complications
- 265 – Biopsy follow-up
- 322 – Cardiac stress imaging not meeting appropriate use criteria (preoperative evaluation in low risk surgery patients)
- 323 – Cardiac stress imaging not meeting appropriate use criteria (routine testing after percutaneous coronary intervention)
- 324 – Cardiac stress imaging not meeting appropriate use criteria (testing in asymptomatic patients)
- 344 – Rate of carotid artery stenting for asymptomatic patients without major complications
- 345 – Rate of postoperative stroke or death in asymptomatic patients undergoing carotid artery stenting
- 347 – Rate of endovascular aneurysm of small or moderate non-ruptured abdominal aortic aneurysms who die while in the hospital
- 409 – Clinical outcome post endovascular stroke treatment
- 413 – Door to puncture time for endovascular stroke treatment
- 420 – Varicose vein treatment with saphenous ablation
- 421 – Appropriate assessment of retrievable inferior vena cava filters for removal
5. Create a Workflow
Make sure that your office staff is on the same page (Hint: you should share this blog post with them!) and establish a workflow that ensures that all staff members understand the measures selected for submission, and the best ways to obtain that information to allow for optimized data capture.
6. Report, report, report!
Regardless of heightened penalties, an increase in reporting choices and radiology-specific measures are counteracting the stress behind preparing for the dreaded PQRS 2016. So explore your options, plan ahead, take a deep breath, and report on!
We're a proud sponsor of The Radiology Business Management Association (RBMA). Visit their website for information on the Annual RBMA Fall Educational Conference, designed to accommodate higher level learning and in-depth coverage of topics affecting the business of radiology today.