Proposed payment schedule includes harmonization of reporting measures

Healthcare providers have long decried the cacophony of reporting requirements under various CMS programs and have asked for harmonization of the rules.

Now, the 652-page proposed rule encompassing changes to the Medicare Physician Payment Schedule, released Monday, may have providers who report clinical quality measures more often singing from the same hymnal in 2014.

Harmonization of reporting has been a goal for the Medical Group Management Association, but “we're not the only ones,” said Robert Tennant, its senior policy adviser. “It's been ridiculous that you have to report the same measures for different programs.”

The most prominent health information technology program affected by the proposed new rule is the federal EHR incentive payment program under the American Recovery and Reinvestment Act of 2009.

For calendar year 2014, physicians and other “eligible professionals” under the EHR incentive program will have the option to use qualified clinical data registries, as defined by the Physician Quality Reporting System, to meet their meaningful-use incentive payment requirements for clinical quality reporting in 2014, according to a CMS summary of the rule changes. To qualify for EHR incentive payments, however, providers still have to use a federally certified EHR and report to the registry those quality measures required by that program.

The American Taxpayer Relief Act of 2012 allows eligible professionals to substitute reporting quality measures to qualified registries as a substitute for reporting quality measures under PQRS, and that revision is covered by the proposed rule, according to the CMS summary.

More than 280,000 physicians and other eligible professionals participated in the PQRS program in 2011, the latest year data are available from the CMS. They received nearly $262 million incentive payments that year. More than 292,000 physicians and other professionals have been paid nearly $6.2 billion under the EHR incentive payment program thus far. That program started paying out money in January 2011.

Another quality reporting harmonization attempt in the new proposed rule involves the Comprehensive Primary Care Initiative, a CMS-sponsored, voluntary program with roughly 500 participating physician practices in eight states. The aim of the program, created under the Patient Protection and Affordable Care Act, is to involve public and private healthcare payers in efforts to strengthen primary-care practices in those areas.

The proposed new payment rule would allow CPCI participants that report at least nine clinical quality measures under that program in three of the five quality reporting “domains” developed by the Agency for Healthcare Research and Quality to be deemed to have met the meaningful-use requirements for quality measures reporting under the EHR incentive payment program.

The public comment period on the proposed rule is open through Sept. 6, with a final rule expected by Nov. 1, according to the CMS.

Tennant said the government has tried to make it easier for physicians to report by adding registries to other approved reporting methods—through claims submissions to the CMS and by direct reporting through an electronic health-record system. But the lag between reporting and incurring a Medicare payment reduction for failing to meet the reporting requirement is still an issue, he said.

"If you're successful in 2014, you avoid the penalty in 2016,” Tennant said. “Obviously, we would prefer the payment adjustment year be based on the year of reporting, instead of a lookback, in this case, two years. But we lost that battle long ago.”

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