Previously we discussed the changes in health care provision regarding the Physician Quality Reporting System (PQRS). In this article I will present more in depth current information regarding the ever changing landscape of medicare reimbursement and how physical therapists fit into the picture. In January of this year, the US department of Health and Human Services (HHS) produced the first set of timelines for a transition away from Medicare reimbursement as we know it. The ball is now rolling to move away from a fee-for-service model in favor of a payment for outcomes paradigm. This new model will create a demand for provider accountability and increased quality in patient care in an outcomes-based reimbursement model.
The major changes in PQRS reporting for 2015 drastic changes in fee schedule payment. Specifically, private practice PTs who did not participate in successful reporting of data on quality measures in the form of PQRS reporting in 2013 will see a 1.5% reduction in their fee schedule payment in the year 2015(1). Those who do not successfully participate this year will be see a 2.0% reduction in their fee schedule which will be fully realized in the year 2017.
Additionally, private practice’s will be included in a Value-Based Modifier (VM) program which is set to begin in 2016. Under this new program, PTs must meet PQRS reporting requirements or be subject to up to a 4.0% reduction in payment in addition to the pre-existing 2.0% reduction for a total of 6.0% reduction in pay which will be realized in the year 2018.
The intention behind all of this change is that health care practitioners, including PTs, will provide higher quality services for Medicare beneficiaries. PQRS reporting began in 2007 and in the year 2011 was re-branded and tuned up through the Affordable Care Act. In 2013 it morphed from an incentive-based program to a penalty based program. There is no going back to where we came from, PQRS is here to stay, and a fixture of outpatient physical therapy practice(2).
Interestingly, the VM program utilizes PQRS data collected from clinicians to determine its penalties. Currently, physicians are experiencing these penalties, though the Center for Medicare Services (CMS) has held off on penalizing allied healthcare professionals in order to give adequate time for us to familiarize ourselves with the reporting system. Next year however, we will be held to the same standards, and in order to continue to draw in revenue as we have in the past, we must be compliant with the reporting format.
The regulations are doable. As PTs we must report at least 9 measures, which includes at least 3 National Quality Strategy (NQS) domains on at least 50% of Medicare Part B fee-for-service patients. A complete list of PQRS registries can be found at: http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/Registry-Reporting.html. Depending on the type of patients your clinic sees, some of the domains may be satisfied rather easily with patient intake forms as these include a complete checked list of medications, a pain assessment prior to initiation of patient treatment, and a functional outcome measure. The first two are easily satisfied with patient intake, and the latter may be performed as part of the evaluation of a new patient, and thus readily satisfy Medicare PQRS requirements.
There are notable changes in the 2015 reporting, including which cases are eligible for reporting. These changes include elimination of the Back Pain measures group, as well as the Wet to Dry Dressing In Patients with Chronic Skin Ulcers. G code G8406 Diabetic Neurologic Evaluation was removed as well, while G codes G8980, G8983, G8986, G8989 and G8992 were added for FOTO outcomes measures #217-2231.
To check your status as a provider, and your clinic’s success in PQRS reporting, the CMS provides claims-based participants with feedback reports through Quality Net, the contracted service provider for Medicare. Visit firstname.lastname@example.org or call 866-288-8912 to verify that you are on track for a successful reporting year. You may also receive feedback in the way of an Individuals Authorized Access to CMS Computer Services (IACS) account from Quality Net. You can set up an account at www.qualitynet.org/portal/server.pt/community/pqri_home/212#.
Of the two methods of reporting PQRS, the registry reporting method is quickly gaining traction. This may be due to increases in claims based requirements. Thankfully, the American Physical Therapy Association (APTA) has several resources available to ensure successful reporting. A comparison of the registry based reporting versus claims based reporting may be found at the APTA website: http://www.apta.org/PQRS/(3).
Additionally, the Physical Therapy Outcomes Registry is reaching finalization and will provide outpatient PTs with an organized system for collecting data to evaluate patient’s function, in addition to other relevant measures1. This collective data will demonstrate the value of physical therapy in the betterment of our patients. Furthermore, this data may be a highly beneficial tool in our continued advocacy for lightened Medicare Caps, better reimbursement, and improved professional image. More information on this registry may be found at: www.PTOutcomes.com.
All things considered, the essence of all of these changes is to provide the highest quality care for our patients. By demonstrating progress in our patients through functional outcomes measures, we are able to show the value that physical therapy holds in the lives of our patients. What we have intrinsically known for decades, we will now be able to show to Medicare, to our patients, and referral sources.
- Smith, H. Compliance Matters. PT in Motion. (8-12) April 2015.
- Registry Reporting . Center for Medicare Services. Available at: http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/Registry-Reporting.html. Accessed on April 20, 2015.
- Medicare Physician Quality Reporting System. American Physical Therapy Association. Available at: http://www.apta.org/PQRS/. Accessed on April 20, 2015.
-Amanda Olson, DPT