The Medicare final rule for the 2014 fee schedule was published on November 27th. Buried in this 1300+ page document were numerous changes to the Physician Quality Reporting System (PQRS) program for 2014.
In 2014, PQRS participation is more important than ever. And the reason for this importance can be summed up in three words: significant financial penalties. Failure to participate in PQRS in 2014 will result in a 2% reduction for all Medicare payments in 2016. Further, if a radiologist is practicing in a group of 10 or more physicians, lack of PQRS participation will result in an additional 2% reduction for all Medicare payments in 2016 through the Value Based Modifier (VBM) adjustment. So, if a radiologist is practicing in a group of 10 or more physicians, failure to participate in 2014 translates into a 4% decrease to all Medicare payments for 2016. And the reward for participation remains a paltry 0.5% of all Medicare payments.
While the changes in 2014 are numerous, the changes applicable to most radiology practices can be summarized with a few key points listed below:
- In order for a radiologist to receive an incentive payment, the radiologist must report on all 9 radiology measures using claims-based or registry reporting. If all 9 measures do not apply (and most radiologists will not perform studies applicable to all 9 measures), the radiologist must report on all studies that apply.
- In order to avoid the PQRS financial penalty of 2% only (no incentive money), radiologists only need to report on 3 measures.
- However, radiologists who practice in a group of 10 or more should be wary of only reporting 3 measures due to the VBM adjustment. The VBM adjustment documentation is very vague at this point. Therefore, the concern is that reporting only 3 measures may not exempt a group from the 2% VBM penalty. Therefore, groups of 10 or more are strongly encouraged to report on all 9 measures. Groups of less than 10 can safely report only 3 measures and avoid all penalties because groups of less than 10 are not included in the VBM program in 2014.
- The radiology PQRS measures for claims-based and registry reporting did not change from 2013 to 2014.
- In 2014, for the first time, radiologists have the opportunity to report on a CT measures group. Radiologists who choose this option must report all 6 CT measures in the measures group on at least 20 patients (the majority must be Medicare patients). However, the documentation requirements for these new CT measures are quite onerous and dependent on the cooperation of the hospital, the IT systems in place at the hospital and even the relationship between the group’s hospital and other local hospitals. Because of the documentation requirements, the CT measures group will be tough to implement for most groups. However, this may be the only option for groups who cannot report on the 9 current PQRS measures that are available by claims and registry reporting.
Wendy Driscoll, MBA
Senior Client Manager