Quick Look: Understanding PQRS reporting requirements for 2015

The Physician Quality Reporting System (PQRS) is often seen as one of the most complex CMS quality reporting programs, in part because of the large number of options that are available to providers participating in the program. Although cold fall air may be upon us, your practice may still be feeling the heat if you haven’t started PQRS reporting in 2015.

While having choices for participation may seem like a positive thing, it also means that eligible professionals must understand the requirements of various reporting mechanisms and then select the one that is best for them, instead of learning a single set of requirements each year. This post will offer a quick look at the reporting requirements for PQRS, then you can deep dive into the reporting options that interest you our in depth posts!

For providers wishing to report PQRS in 2015, there are five reporting mechanisms to choose from for reporting quality measures to CMS:

The reporting requirements for each mechanism differ, sometimes in small ways, so it is important to understand the requirements necessary for each reporting option to select the one that is best for your practice.  For example, not all quality measures can be reported via each reporting mechanism, which means your practice will need to select a group of quality measures that is applicable to your practice while also evaluating the different reporting mechanisms that are available.

PQRS reporting mechanisms comparison table

Click or tap table to view larger.

Avoiding the PQRS Payment Penalty

In 2015, the PQRS program requires providers reporting individual measures under any mechanism to report at least 9 quality measures covering at least 3 National Quality Strategy domains. For each measure, you must report for at least 50% of applicable Medicare Part B patients seen during the calendar year. If you’ve reported in past years, you know that providers had the option to report a certain number of quality measures to earn a payment incentive or a smaller number of measures to simply avoid the payment penalty. This year, because there is no incentive payment, there is only one set of requirements.

If you cannot report 9 measures due to lack of measures applicable to their specialty can report fewer than 9 for the required number of patients and still avoid the penalty. However, they will be subject to additional evaluation by CMS under the Measure Applicability Validation (MAV) process to ensure there were not other eligible measures to report.

Cross-Cutting Quality Measures

In addition, providers who bill for at least one face-to-face encounter during the 2015 calendar year and opt to report PQRS via the claims or registry reporting mechanism must report at least one cross-cutting measure as part of the total reporting requirements in order to avoid future payment penalties. Cross-cutting quality measures are non-disease specific measures designed to encourage preventive care and care coordination for all Medicare beneficiaries.

The cross-cutting measures address topics such as: tobacco use, immunizations, preventive care, medication reconciliation, functional outcomes assessment, and pain assessment. CMS defines a face-to-face encounter as an instance in which the provider billed for services that are associated with face-to-face encounters under the Physician Fee Schedule (PFS). This includes general office visits, outpatient visits, and surgical procedure codes but not telehealth visits.

If this overview of PQRS reporting mechanisms leaves you with more questions, please take a moment to send those questions to Able! We promise to respond to your question. You can also see more detailed information on each reporting mechanism in our PQRS reporting mechanism deep dives:

Further reading:
Submitting MIPS through the new CMS website: what it can and can’t do
Downloadable Tool! The 2017 MIPS Submission Checklist

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