Still Time to Participate in 2014 PQRS Program

CMSOn January 13, 2015, CMS conducted a call providing further details on the electronic submission options available for the 2014 PQRS program. Presentation materials from this call are available on the CMS website. To obtain further details on PQRS, visit Medicare’s PQRS homepage.

It is not too late to participate in the 2014 PQRS program and earn a bonus payment for 2014 and avoid a penalty in 2016. While the claims-based reporting option is no longer available, on January 1, 2015, the CMS opened up several electronic submission options. Providers can choose one of these options to submit data for the CY 2014 PQRS reporting year.

PQRS is a quality reporting program that uses a combination of incentive payments and negative payment adjustments to promote reporting of quality information by eligible professionals. The Affordable Care Act (ACA) authorized bonus payments through 2014. Eligible providers can earn an incentive payment equal to 0.5 percent of their total estimated Medicare Part B Physician Fee Schedule allowed charges for the CY 2014 reporting year. Providers are also eligible to earn an additional incentive of 0.5 percent by working with a Maintenance of Certification (MOC) entity to meet the additional MOC requirements. Further details on the MOC incentive are available on the CMS website.

The ACA also called for payment penalties beginning in 2015. There is a two-year lag period between the reporting period and the year the penalty is applied. Eligible providers that do not participate successfully in PQRS in 2014 will see their Medicare payments cut by 2 percent in 2016. CMS released a document providing details on the 2016 payment adjustment and the criteria for successful participation. An additional inducement for provider participation in PQRS beyond the bonuses and risk of penalties is that CMS has begun to use PQRS as a proxy for quality for other Medicare initiatives, such as the Electronic Health Record (EHR) Incentive Program, quality reporting for Accountable Care Organizations and the Value-Based Payment Modifier.

Providers participating individually can still submit data for 2014 through the following reporting methods:

Reporting Method Reporting Deadline
Qualified PQRS Registry March 31, 2015
Certified EHR Technology (CEHRT)

EHR (Direct Product Submission)

February 28, 2015
EHR Data Submission

(Vendor that is CEHRT)

February 28, 2015
MOC Incentive Program March 31, 2015

Registration for group practice reporting through the Group Practice Reporting Option (GPRO) ended October 3, 2014. Groups that registered for the GPRO by the October 2014 deadline can submit their data from January 26, 2015, to March 20, 2015.

Qualified PQRS Registry Reporting Option
Submission information on the 2014 Qualified PQRS Registry reporting option can be found here.

QCDR Reporting Option
The 2014 QCDR Submission Overview document provides information on the submission process for the QCDR reporting option. CMS has also posted a document on its website that contains a listing of 2014 QCDRs, including detailed information on the services each QCDR offers, the cost incurred by their clients, and the measures they support for the 2014 PQRS reporting year.

EHR Reporting Options
Providers have two options for CEHRT-based reporting: submit PQRS quality measure data directly from the CEHRT, or submit PQRS quality measure data extracted from the CEHRT to a qualified EHR Data Submission Vendor. More information on the CEHRT-based reporting options is available on the CMS website.

Source: McDermott + Consulting Insights

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