52 MONITOR ON PSYCHOLOGY • SEPTEMBER 2014
Practice PERSPECTIVE ON
Overcoming the challenges of PQRS
BY DR. KATHERINE C. NORDAL • EXECUTIVE DIRECTOR FOR PROFESSIONAL PRACTICE
Value trumps volume in the evolving health-care system. In an effort to
improve the quality of patient care, the Centers for Medicare and Medicaid
Services (CMS) is strongly encouraging health-care providers to report
quality measures on their patients. However, the complex reporting
requirements of these programs can be daunting for psychologists.
CMS introduced the Physician Quality Reporting System
(PQRS) in 2007 as an incentive- and penalty-based payment
program in which eligible Medicare providers report data on
quality measures for covered professional services provided to
Medicare beneficiaries. The system includes measures aimed
at promoting long-term health, such as preventive care and
screening for clinical depression. Since 2007, the APA Practice
Organization (APAPO) has been working to educate members
about reporting program requirements. Psychologists who
don’t participate in 2014 by reporting PQRS measures for more
than 50 percent of their applicable Medicare patients may face a
2 percent Medicare payment penalty in 2016.
To facilitate participation in PQRS, APAPO is exploring
options to partner with a qualified registry for psychologists. A
registry is an electronic system that allows eligible professionals
to enter quality-measurement information for PQRS. The
registry will collect clinical quality data, through a web-based
program, spreadsheets and/or electronic health records. A
registry would be responsible for calculating and submitting
quality measures data to CMS in a specified format on behalf
of the eligible professional or group practice for the respective
program year. A list of registries qualified to submit PQRS data
appears on the CMS website.
Although not used as often as claims-based reporting by
mental health professionals, registries are an important option
for psychologists to explore following the decision by CMS to
make some measures ineligible for claims-based reporting in
2014 and beyond.
Two individual measures previously reported by
psychologists through claims — No. 9 (Antidepressant
Medication Management) and No. 173 (Unhealthy Alcohol Use
Screening) — now must be reported through either a registry
or electronic health records. In addition, all measures groups,
including the dementia measures group, must now be reported
via a registry. Measure No. 325, Adult Major Depressive Disorder,
Coordination of Care of Patients with Specific Comorbid
Conditions, has always been limited to registry reporting.
For 2014, registry and claims-based reporting have the same
requirements: Providers must report nine measures across three
domains for 50 percent of the eligible professional’s applicable
Medicare cases. Providers who report fewer than nine measures
will have their data reviewed under the Measure Validation
Process (MAV) to determine if additional measures could have
been reported. If the MAV review indicates that the requirement
to report nine measures across three domains requirement
could not have been met, then the provider will not incur the 2
percent penalty in 2016.
Providers who use a registry can save time since they no
longer need to manually add PQRS measures and codes to
claims. In addition, they can submit the data as late as February
of the following year. Registries automatically update the list of
PQRS measures annually. Costs vary, but psychologists should
expect to pay at least $250 annually to report through a registry.
It is important to verify that a registry can support all of the
measures on which a psychologist might report.
Resources for practitioners starting out in PQRS appear on
APAPO’s Practice Central website (www.apapracticecentral.
org). They include:
• Updates to Medicare’s Physician Quality Reporting System.
• Quick Reference Guide for PQRS Measures, Procedure
Codes and G-codes.
• PQRS Measures for 2014.
• PQRS: Questions and Answers for Psychologists.
If you have questions about participating in PQRS, contact
your local Medicare contractor or APAPO at (202) 336-5889 or
firstname.lastname@example.org. APAPO will continue to monitor changing
requirements and advise members of important information
online and through our PracticeUpdate e-newsletter. n