Physician Groups Take on Fee Schedule’s ‘Quality Reporting’ Plans

September 2, 2011

Electronic submission of clinical quality measures was one of the chief concerns voiced by healthcare organizations.

Healthcare associations this week submitted concerns and suggestions to CMS regarding its proposed rules for the2012 Medicare Physician Fee Schedule.

Among the chief grievances of the 176-page proposed rule - and there were more than can be included in a single blog posting - were those related to electronic submissions of clinical quality measures.

In a letter to CMS Administrator Donald M. Berwick, the HIMSS Electronic Health Record Association (a consortium of 42 EHR suppliers) voiced its hesitation to embrace CMS’ plans for a pilot program that would require the submission of patient-level data. This would place a burden on provider organizations, according to the association.

Mark Segal, current member and former vice chair of HIMSS EHR committee, who is also vice president of government and industry affairs at GE Healthcare IT, said the proposed fee schedule called for a pilot program for electronic reporting of “meaningful use” quality measures that would involve a new, untested method of recording and sending patient quality measures. Currently, providers attesting for Stage One of CMS’ meaningful use program submit aggregate-level data from their entirepatient population - providers compute a numerator and a denominator based on how many patients achieve the measure, and submit that information electronically.

Under the proposed pilot, physicians would have to report patient-specific data for select Medicare patients, says Segal. This is a more cumbersome process.

“The concern with submitting the raw data is several-fold. It adds a level of complexity,” Segal told Physicians Practice. “It can potentially introduce privacy considerations, it can lead to the use of fairly large data files, which can be unworkable, and it leads CMS down paths that are undesirable for quality reporting.”

The use of only Medicare data would also give an incomplete view of how a provider is performing, Segal said.

Meanwhile, American Academy of Family Physicians also commented on a number of recommendations detailed in the proposal, and made its own recommendations to improve CMS’ quality reporting initiatives.

Tucked in its 26-page letter to Berwick, AAFP Board Chair and physician Lori Heim called for improving CMS’s Physician Quality Reporting System (PQRS), the program aimed at delivering payment incentives to physicians who successfully report data on quality measures during a specific reporting period.

In the letter, Heim suggested that CMS:
 

• continue to offer as many PQRS reporting options and timeframes as possible to facilitate successful participation by small to medium-sized groups;
• allow physicians to form "virtual" groups for PQRS reporting proposes;
• accelerate the requirement definition and the review process for qualifying PQRS registries;
• hold vendors accountable for successful data submission; and
• minimize administrative burdens if physicians are required to report on PQRS core measures that focus on cardiovascular conditions and only use measures endorsed by the National Quality Forum.

The AAFP also urged CMS to refrain from basing the 2015 PQRS penalty on 2013 performance, and provide physicians with more timely access to PQRS feedback reports.

"The current 18-24 month lag time between the point of care and access to a feedback report is fundamentally not helpful from a quality improvement perspective," said Heim, in a press release. "If the PQRS program is truly intended to improve the quality of physician services, the AAFP believes CMS must begin offering timelier (monthly or quarterly) interim feedback reports to PQRS participants."

As we noted earlier, these quality-related concerns are only the first of many qualms physician groups had with the 2012 proposed fee schedule. As additional comments roll in about other parts of the mammoth document, we’ll keep you posted.