DATA SUBMISSIONS AND FEEDBACK REPORTS
How is PQRS data reported to CMS?
There are actually several methods by which participation data can be submitted, but the two most common methods are claims-based reporting and registry-based reporting. In claims-based reporting, CPT II bills are generated to indicate the providers’ answers to the PQRS measures and those CPT II bills are submitted through your billing company along with the original encounter to which the PQRS reporting applies. There are several drawbacks to claims-based data submission, and it has generally proven to be an unreliable method of reporting. Registry-based reporting is a more modern approach to data submission. A certified PQRS registry retrospectively analyzes the data for each provider across the entire participation period and transmits a summary of their participationt data directly to CMS through a secure portal. The registry-based reporting method is considered a much more reliable method of data submission than claims-based reporting.
What is a PQRS registry??
A PQRS Registries are certified by CMS after an extensive vetting process that includes verification of expertise in measure implementation, validation of processing of physician responses and confirmation of the ability to submit performance data in accordance with established CMS guidelines. PQRS registries analyze participation data after the reporting period has concluded, then compiles the reporting and performance statistics for each participating provider. The registry then transmits those figures directly to CMS through a secure online portal. Registries also provide participation reports to the practices for which they submit participation data.
Why is registry-based reporting better than claims-based reporting?
- Claims-based submission attempts to use a billing system to send non-billing information and provides no feedback on transmission success (aka “message in a bottle”).
- CPT II bills must accompany the bills that represent the opportunity to report quality measures:
- Must arrive on same claim.
- Must have same Patient Identifiers, NPI, and DOS.
- Must be passed through by the billing company:
- Must contain a zero charge (or, if billing software does not allow 0 charge, 1 cent is allowable).
- All charges will be rejected for payment, but “should” be passed through by the carrier for reporting purposes.
- Claims cannot be resubmitted for the sole purpose of reporting PQRS or altering PQRS responses.
- Report at least 3 measures for at least 50% of applicable Medicare Part B FFS patients seen during the reporting period (or all measures that apply if <3 apply).
- Performance feedback delayed until October of the following year.
- Claims-based submission has historically resulted in success rates around 50%.
- Some CPT II codes have inadvertently been rejected by the MACs in previous participation period (the reporting events missed in these cases is irretrievable via claims-based reporting)
- Registry-based submission involves a retrospective analysis of the previous year’s data (filed in Feb/March of the following year).
- Registries undergo an extensive vetting process in order to qualify for submitting.
- All reporting is tallied (by TIN/NPI), reporting and performance rates calculated, and resulting data is transmitted directly to CMS via secure web portal (immediate confirmation of “mission accomplished”).
- Only aggregated performance data is reported (no patient information is included).
- Report at least 3 measures for at least 80% of applicable Medicare Part B FFS patients seen during the reporting period (or all measures that apply if <3 apply).
- Registries can provide the same reporting and performance data to the group as they provided to CMS, so a reliable estimate of success is available immediately (but registry filing does NOT shorten the reimbursement time table).
- Groups can opt into the registry service at any point during the participation period (assuming they have been collecting PQRS information throughout the participation period).
- Registry-based submission has historically resulted in success rates greater than 90%.
Can I submit both claims-based and registry-based data in the same participation period?
Yes. CMS allows data submission by both claims-based reporting and registry-based reporting. If a provider submits participation data through both methods, CMS will evaluate the data from each submission method separately, and the data that most favorably reflects on the physician’s participation will be used (the data received from the registry and through claims will not be combined). Under these circumstances, filing your PQRS data through IM’s certified PQRS registry service can only help your group succeed, and could never hurt your chances for success. Because of the way the separate data streams are evaluated, submitting participation data through both methods is NOT considered “double dipping” by CMS with respect to reimbursements.
Can we stop the flow of claims data after activating the registry service?
Claims-based reporting data can be blocked at the billing interface for clients using automated billing feeds, but this would require custom development work at an additional charge. There are actually several reasons that it is advantageous to continue the flow of claims-based reporting data in addition to filing through the registry. Claims-based data and registry-based data are evaluated independently by CMS, and the minimum successful reporting requirements for claims-based submission is lower than that of registry-based submission (50% versus 80%, respectively). In some circumstances, providers who were not successful based on registry data could potentially participate successfully for the entire year’s reimbursement based on their claims data submission.
How do we get our participation reports from CMS for PQRS reporting?
If you do not currently have an IACS account, you will need to establish one in order to access your group’s report. Registration instructions can be found clicking here to access the MLN Matters article by CMS. The IACS site is not generally considered very “user friendly”, and IM can assist you with navigating the registration process if necessary. Once you have an IACS account, you will be able to log into the QualityNet portal and request participation reports.
To access their individual feedback reports, providers do not have to have an IACS account. They can also obtain the report by clicking here and requesting it on-line directly from CMS. Each provider needs to complete the request for their individual NPI.
For providers who participate in IM’s PQRS Registry service, an individual participation report will automatically be mailed to the provider if they had a valid email address on record within the Ingenious Med application at the time of data submission.
Can Ingenious Med assist us in interpreting our CMS reports?
Ingenious Med has extensive experience interpreting the CMS PQRS participation reports, and we invite you to contact us if you would like to spend some time discussing the implications of your report. Please contact your Account Manager or Technical Support if you would like to set up conference.
What’s the difference between a physician’s “Reporting Rate” and “Performance Rate” on a measure (and why does each matter)?
Reporting Rate for a given measure is the percentage of triggers for which we have an answer on record (including our default “unknown” answers, which equates to “did not perform the measure action” for reporting purposes). Since PQRS is (for the most part) still “pay-for-reporting”, Reporting Rate is the criteria reimbursement payments and negative payment adjustments reference.
Performance Rate for a given measure is their ratio of good care to bad care based on the answers provided by the MD. It is not currently used for reimbursement, but these are the ratings CMS will post to the Physician Compare website, so the physician’s Performance Rate could still directly affect the bottom line for their practice. While PQRS is technically still “pay-for-reporting”, any measure with a 0 performance rate for the participation period will not count towards that provider’s 3-measure minimum for successful participation.
What PQRS reports are available from Ingenious Med?
- Basic (Site-level) tracking reports will be available in the application by the end of 2012.
- In-depth reports (Provider/Measure-level) are available through IM’s premium Imagine reporting service.
- PQRS Registry participants will receive participation feedback reports from IM at the conclusion of the data submission period.