PT Management Support Systems, which provides physical therapy consulting and management services for orthopaedic groups, is providing the following guidance regarding how orthopaedic groups should handle their PQRS reporting for 2016.
At the beginning of 2015, we recommended that orthopaedic groups use the group practice reporting option (GPRO) for 2015 PQRS reporting and have physicians report their measures, rather than having the therapists (and other providers) report individual measures. This option allowed not only the physicians to avoid negative payment adjustments, but also covered therapists, PAs and other providers because the GPRO basically provides that if the physicians report on 50% or more of the group’s Medicare patients, all of the other providers in the group are covered.
This recommendation remains the same for 2016 reporting and frankly makes even more sense because the physician penalties for not reporting have only increased.
Potential Penalties. Failure to report PQRS measures in 2016 will result in the following percentage decreases (“adjustments”) in Medicare payments for 2018 dates of service:
- 2% for PQRS which applies to physicians, PAs, NPs and therapists
- 3% for EHR meaningful use failure which only applies to physicians (physicians can meet the CQM requirements for meaningful use through PQRS reporting)
- 4% for the Value Based Modifier which applies to physicians, PAs, and NPs, but not therapists
Individual Reporting Option. Each of your physicians, PAs, NPs and therapists can individually meet PQRS requirements by reporting on a minimum of 9 measures for at least 50% of his or her Medicare patients. When providers report individually, rather than as a group using the GPRO election discussed below, each provider is tested individually. (PTs need to report on 8 measures if you report via registry.)
Group Practice Reporting Option (GPRO). If you make the GPRO election, PQRS reporting is measured at the group level. For example, if your group has a total of 1,000 traditional Medicare patients during 2016 and the physicians report at least 9 measures for at least 500 of these patients, the 2016 reporting requirements are met for the entire group, including physicians, PAs, NPs and therapists. (PQRS reporting only applies to traditional Medicare patients, not Medicare Advantage patients.)
The following are some of the basic GPRO requirements:
- If you want to use the GPRO, you must file a GPRO election for 2016 reporting by 6/30/16
- PQRS data can be reported via registry, EHR, clinical data registry, or GPRO Web Interface, but not via claims (most groups will use registry or EHR reporting)
- EHR reporting will allow you to meet CQM requirements for meaningful use
- You can only report individual measures, not measures group
- You must generally report 9 measures in 3 domains for at least 50% of your traditional Medicare patients, but PQRS reporting can be reduced to 6 measures over 2 domains if you do a CAHPS survey (discussed below)
CAHPS (Consumer Assessment of Healthcare Providers and Systems)
- Physician groups with over 100 providers (including physicians, PAs, NPs and therapists) must hire a CMS-approved third-party survey firm to conduct a yearly CAHPS (Consumer Assessment of Healthcare Providers and Systems) survey to measure patient experiences and satisfaction.
- Groups with less than 100 providers have the option of doing a CAHPS survey.
- If your group does a CAHPS survey, PQRS requirements can be satisfied by reporting on 6 measures over 2 domains, rather than 9 measures over 3 domains (however, if you use the GPRO Web Interface, you must report on all patients in the pre-populated patient sample).
- If your group will be doing a CAHPS survey, you must indicate this in your GPRO election.
- Although CMS’s guidance regarding CAHPS surveys states that the survey is not appropriate for groups that do not provide primary care services, We have confirmed with CMS that orthopaedic groups with 100 or more providers are required to do a CAHPS survey, orthopaedic groups with less than 100 providers have the option to do a CAHPS survey, and that even if these groups do not have a sufficient number of primary care patients to report for CAHPS, they still only need to report on 6 PQRS measures.