PQRS Update: More Changes, More Choices

As we have reported in the past, The Physician Quality Reporting System (PQRS) saw numerous changes in 2014.  The most significant of these changes were as follows:

  1. In order to receive a PQRS incentive payment, physicians must report on at least 9 measures (not 3 measures as in years past).
  2. In order to avoid PQRS penalties, physicians must report on at least 3 measures.

However, there were a number of smaller changes that have been published in the last few months that will impact participation as well.  We have listed the most substantial changes and clarifications below:

1.      New Option for Radiologists to Participate in a Qualified Clinical Data Registry through the ACR

There is a new option for radiologists to participate in PQRS through a Qualified Clinical Data Registry (QCDR) through the American College of Radiology (ACR).  The QCDR is a new option for 2014 that allows physicians to report on PQRS measures and additional ‘non-PQRS measures’ through specialty specific PQRS registry reporting.  This particular QCDR is particularly appealing for radiologists who have not yet begun PQRS reporting and/or have a limited number of applicable PQRS measures for which they can report.  Additional information regarding the ACR’s registry can be found at the following link:


Break Away from the Static

2.      N365 Remark Code Retired

On July 1st, CMS officially retired the N365 remark code and replaced it with the N620 or N572 remark code.  Per the June 17th announcement on a MLN Connects National Provider Call, “Eligible professionals who bill on a $0.00 Quality-Data Code (QDC) line item will receive the N620 code, which replaces the current N365 code. Also, eligible professionals who bill on a $0.01 QDC line item will receive the CO 246 N572 code.”

While the N365 remark code was officially retired on July 1st, some Medicare Administrative Contractors (or MAC’s) began using the new remark codes as early as April 1st.  PQRS participants using claims-based reporting should watch closely for these new remark codes.

3.      Value Based Modifier Adjustment Clarified

  1. For the Value Based Modifier (VBM) adjustment, which is another adjustment associated with PQRS participation for groups of ten or more physicians, CMS has clarified that no VBM penalty will be incurred as long as 50% or more of physicians in a group avoid the PQRS penalty.
  2. The VBM adjustments range between a -2% adjustment to a +2% adjustment.  The VBM adjustment can also be neutral.  Unlike the PQRS penalties and incentives, which are straightforward percentages and published prior to the participation year, the VBM adjustments must be budget neutral.  Therefore, a group’s VBM adjustment will depend on the PQRS participation and comparison to other physicians.

For additional information regarding PQRS, please visit www.radadvocate.com or contact me directly at 614-210-1852.

As always, ADVOCATE will keep you updated on this and other issues impacting radiology as they become available.

Best regards,
Wendy Driscoll, MBA
Senior Client Manager