Medicare Physician Reporting: Beyond PQRS. Mary Patton Wheatley Senior Specialist, AAMC August 17, 2011

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1 Medicare Physician Reporting: Beyond PQRS Mary Patton Wheatley Senior Specialist, AAMC August 17, 2011

2 Who is the AAMC? The Association of American Medical Colleges (AAMC) serves and leads the academic medicine community to improve the health of all.

3 Who Does the AAMC Represent? All 135 accredited U.S. and 17 accredited Canadian medical schools Nearly 400 major teaching hospitals and health systems; including the VA Nearly 90 academic and scientific societies 125,000 faculty members, 75,000 medical students, and 106,000 resident physicians

4

5 Improving Value in the Medicare Program Current FFS (Mandatory) HAC (current) Hospital VBP (FY 2013) Readmissions (FY 2013) HAC (FY2015) Physician value modifier (2015/2017) Payment Unit Aggregation (Voluntary except for ESRD) ESRD Bundled Payment ( ) Payment Bundling Demo (nlt ) Acute care episode (ACE) Demo (2009) Population-Based Payments (Voluntary) PGP Demo (2005) ACOs (2012) Medicare High Cost Bene Demo (2004) Medicare Advantage CMMI initiatives

6 Medicare s Road to High Value Healthcare Voluntary reporting Pay-for- Reporting (and public reporting) Pay-for-Quality Performance Pay for Higher Value Value = ƒ(quality, Efficiency) Physician Feedback Program (Resource Use) Physician Value Modifier Happy Place Affordable Quality Healthcare Physician Quality Reporting Physician Compare Inpatient Quality Reporting Hospital Compare Hospital VBP Readmissions Healthcare Acquired Conditions 6

7 Improving the Data Collection/ Reporting Infrastructure Charts Charts Claims Patient Experience Reporting Portals Interconnected Data Sources Claims Other Clinical Sources EHR Incentive Programs E-prescribing Incentive Program Other Clinical Sources Patient Experience 7

8 Medicare Quality/Value Programs Potential Incentives PQRS 0.5% 0.5% 0.5% OR PQRS MOC Option 1.0% 1.0% 1.0% erx Incentive a 1.0% 0.5% OR EHR Incentive Varies Varies Varies Varies Varies Potential Reductions erx Incentive -1% -1.5% -2% PQRS -1.5% -2.0% -2.0% EHR Incentive -1.0% -2.0% -3.0% Value modifier c TBD TBD TBD Total Possible Reduction -1% -1.5% -2% -2.5%+ -4%+ -5%+ 8 a Cannot receive the Medicare EHR Incentive and erx incentive, but can receive both Medicaid EHR Incentive and erx Incentive b Opportunity to recoup full amount and more. c Adjustment could be positive or negative.

9 Medicare Reporting Flowchart Inputs Claims analysis (no additional reporting) PQRS (claims, registry, EHR, GPRO) erx Events In the Incentive Program EHR Incentive Program Category Cost Quality erx Other EHR functions Outputs Feedback Reports Value Modifier Physician Compare How to align the reporting components?

10 Quality: PQRS, MU or Both? Physician Quality Reporting System (PQRS) Program start Eligibility Measure selection Physicians plus several nonphysician practitioners Eligible professional (EP) selects measures Reporting level Individual or group Individual only Reporting period 12-months; limited 6-month option Mechanism Claims, Registry, EHR Attestation Medicare EHR Incentives reporting for Clinical Quality Measures (CQM) Physician (M.D. or D.O.), dentist, podiatrist, optometrist, chiropractor EP reports 3 core/alt core measures plus 3 additional measures 90 days (1 st year); CY thereafter Proposed Alignment for Individuals: PQRS-Medicare EHR Incentive Pilot Program for 2012: Single data submission meets requirements for CQM and PQRS Aligned measures across programs 10

11 Quality: To Group or Not Alignment issue: PQRS and erx Incentive program have a group practice reporting option (GPRO). EHR Incentive programs do not. GPRO included in many recent proposals. Physician Compare Resource Use Value Modifier ACO 2012 GPRO participants are the first to publicly report performance data Special resource/ benchmark reports for the 2010 GPRO participants 2012 GPRO measures included in the list of possible quality measures Many proposed quality measures based on GPRO methodology 11

12 What Are Academic Members Saying About GPRO? Positives Took the guessing out of what to report for each physician Relatively easy compared to claims-based reporting Immediate performance feedback through reporting tool (although incentive check & benchmark data did not come early) Challenges Some patients attributed to practice based on specialty care or referrals Intensive 5-week period to complete data submission Measures mostly primary care what is the role of specialists? Reactions to GPRO based on the experience of 4 academic medical groups

13 E-prescribing Programs erx Incentive Program Program start 2009 (MIPPA) 2011 (ARRA) Medicare EHR Incentives for Meaningful Use Measure Report erx occurring during an encounter > 40% of all permissible rx are transmitted electronically E-prescribing System Qualified e-prescribing system Certified EHR Incentives Available through 2013 Start in 2011 Penalties applied onward 2012 penalties based on 2011 reporting Alignment Issue: EPs that receive Medicare EHR incentives cannot receive erx incentives but could be subject to erx penalties. 13

14 Proposals to Align erx For 2012 Penalty Late proposal to create a significant hardship exemption to exempt providers if they plan to be meaningful users (MU) in 2011* For 2013/2014 Penalty Hardship exemption for MU goes away -- must report to avoid the penalty BUT Changes qualified e-prescribing system to include certified EHRs Can report via claims, registry or EHR *One of 4 proposed hardship exemptions 14

15 Determining Value Inputs Claims analysis (no additional reporting) PQRS (claims, registry, EHR, GPRO) erx Events In the Incentive Program EHR Incentive Program Category Cost Quality erx Other EHR functions Outputs Feedback Reports Value Modifier Physician Compare

16 Measuring Cost & Quality Physician Feedback Program on Resource Use Expanding pilot (Fall 2011) Group reporting for the 2010 GPRO I participants Expanded reporting to individual physicians in Iowa, Kansas, Missouri, and Nebraska Resource use: Per capita measures (Part A & B) Medicare currently developing episode grouper Quality: 2010 PQRS results Additional claims-based measures 16

17 Value Modifier Starting in 2015 for certain practices and 2017 for all practices, CMS is required to pay differentially based on quality and cost composites modifier based on 2013 performance period 17 Proposed Quality Measures 1. PQRS Core Measure set 2. PQRS GPRO Measures 3. Medicare EHR Incentive Program measures Seeking comments on: Outcome measures (hospitalization rates) Care transition measures Patient safety/experience/ functional measures Federal Register pp Proposed Cost Measures 1. Total per capita 2. Total per capita for COPD, heart failure, coronary artery disease, and diabetes Potential future measures: Episodes of care Consider short-term MS-DRG measure

18 What s Missing Lack of standards for efficiency measurement Measure gaps No patient satisfaction/experience data in PQRS, proposed value modifier Limited outcome/care coordination measures Specialty-specific measures Tension between selecting measures for national priorities and measures relevant to specialists/subspecialists

19 What s Next Quality Shift to outcome measures Patient experience measures Patient safety measures Evaluating care across transitions Efficiency Increased focus on total spending/patient per capita; episode of care ; hospitalization episode Increased Data Sharing and Reporting Stage 2 and 3 of meaningful use Developing Health Information Networks E-specifications for measures

20 Continued Challenges Ensuring quality/validity of data as systems transition to electronic reporting Preventing unintended consequences Health disparities Complex patients Methods: Risk adjustment Attribution Benchmarks Aligning with other payers

21 Physician VBP Timeline EHR meaningful use incentives start Test episode groupers Scale up feedback reports 21 Implement the VM through rulemaking Physician Compare with performance data (proposed 2012 GPRO) Select episode grouper Identify measures of cost and quality Specify initial performance period for VM (CY 2013 proposed) erx penalties start CMS plan to align PQRS and EHR reporting (proposed PQRS-Medicare EHR Pilot) VM applies to select physicians and physician groups* PQRS* and Meaningful Use penalties begin VM applies to all physician and physician groups * CMS proposes to use CY 2013 as the performance period for the 2015 VM and PQRS penalty

22 Contact Information Mary Patton Wheatley

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