It is not too late to participate in the Centers for Medicare & Medicaid Services’ (CMS) 2009 Physician Quality Reporting Initiative (PRQI). Participation is voluntary, but providers who participate now will better prepare themselves for probable future reporting requirements while qualifying for an incentive payment from CMS. PQRI rules and details are available at www.rheumatology.org/practice/pqri. There are nine possible options to report data to CMS for PQRI, and six of these can be used by those starting PQRI mid-year.
Below are four simple steps to help you choose the best method for reporting this data. You can find more information in the CMS’ 2009 Physician Quality Reporting Initiative Implementation Guide, located at www.cms.hhs.gov/PQRI/Downloads/2009_PQRI_ ImplementationGuide_040909.pdf.
Step 1: Become familiar with the specific parameters of the measures that might apply to your practice. Although rheumatologists and other eligible rheumatology health professionals can choose to report on any of the 153 PQRI 2009 measures, many will choose the rheumatoid arthritis measure group. Other measures most applicable to rheumatology include screening and management of osteoporosis, assessment of pain, osteoarthritis, falls, back pain, and use of health information technology (such as an electronic health record). Measure specifics are available at www.rheumatology.org/practice/pqri/measures_index.asp.
Step 2: Select the measures and time period on which you would like to report. Select measures based on your patient mix. Then, consider if you will report for a six- or 12-month period. Even for those starting PQRI mid-year, there are options you can use to report for the entire calendar year and receive the full bonus payment of 2% of your 2009 Medicare Part B billings.
Step 3: Select a method to transmit the information to Medicare. Information can be transmitted to Medicare via claims or a CMS-approved registry. Claims-based reporting involves using reporting worksheets. These forms can facilitate claims-based reporting by walking you through the steps to assign the correct code for each measure. The ACR Web site has catalogued these worksheets at www.rheumatology.org/practice/pqri/tools.asp. These worksheets list the appropriate codes, and rheumatologists who choose to participate by reporting quality-measures data through claims can simply report the appropriate quality data codes on service lines of Part B Physician Fee Schedule professional-services claims. Claims-based reporting requires that you submit the quality codes at the same time that you submit the claim for professional services. Medicare has also provided a tip sheet, updated in April, available online at www.cms.hhs.gov/PQRI/Downloads/pqri_satisfactorily508.pdf.
Registry-based reporting requires that providers select a registry that has been approved by CMS as a qualified registry for data collection and submission. This is expected to become the favored method for many providers because they can review the data and add key clinical information concerning the patient at any time. Additionally, providers don’t need to select CPTII codes for registry reporting because the registry performs the measure calculations, and performance data are submitted separately from the billing process.
The ACR has partnered with Outcome Sciences to create the Rheumatology Clinical Registry that facilitates registry-based reporting.
Step 4: Adapt your office workflow and charting to record the information required for successful reporting of these measures. Rheumatologists who are not routinely collecting this information will need to adapt their office workflow. Some practical workflow modifications to consider include:
- Use a patient-completed functional assessment questionnaire, such as the Multi-Dimensional Health Assessment Questionnaire, which is available for download at http://mdhaq.org.
- Record pain using a Likert or visual analogue scale (VAS)—zero to 100 mm. You can incorporate this into the functional assessment questionnaire.
- Record a composite assessment of disease activity in patients with RA. There are many acceptable instruments that do this, including the Disease Activity Score in 28 joints (DAS28), Simplified Disease Activity Index (SDAI), Clinical Disease Activity Index (CDAI), Rheumatoid Arthritis Disease Activity Index (RADAI), and the Routine Assessment Patient Index Data (RAPID).
- Record an assessment of prognosis in rheumatoid arthritis.
- Record a physician and patient global assessment of disease activity. One useful method of doing this is to use a zero to 10 scale and categorize as follows: zero = remission; one to three = low disease activity; four to six = moderate disease activity; and seven to 10 = high disease activity.
These workflow modifications can be achieved by creating forms and templates for your notes or problem lists that are not only convenient, but can serve as reminders. The current reporting requirement is for these assessments to be made once every 12 months, but you may choose to record these as often as you deem clinically relevant.
If you have questions about PQRI reporting, contact Melesia Tillman at (404) 633-3777, ext. 820, or [email protected]. If you have questions about the ACR’s Rheumatology Clinical Registry, contact Amy S. Miller at (404) 633-3777, ext. 813, or [email protected].
Individual Measure Reporting Options
- Claims-based: (January 1 start date)
- Successfully report three or more measures for a minimum of 80% of applicable Medicare Part B fee-for-service (FFS) patients between January and December 2009.
- Registry-based: (options for mid-year PQRI start)
- Successfully report a minimum of three measures for a minimum of 80% of applicable Medicare Part B FFS patients between January and December 2009.
- Successfully report on a minimum of three measures for a minimum of 80% of applicable Medicare Part B FFS patients between July and December 2009.
Measures Group Reporting Options (including rheumatoid arthritis)
- Claims-based: (January 1 start date)
- Successfully report on a minimum of 30 consecutive patients in the group between January and December 2009 (Medicare patients only); or
- Successfully report on a minimum of 80% of patients in the group with a minimum 30 patients between January and December 2009 (Medicare patients only).
- Claims-based: (option for mid-year PQRI start)
- Successfully report on a minimum of 80% of patients in the group with a minimum 15 patients between July and December 2009 (Medicare patients only).
- Registry-based: (options for mid-year PQRI start)
- Successfully report on a minimum of 30 consecutive patients in the group between January and December 2009 (Medicare and non-Medicare patients allowed); or choose one of the following two options:
- Successfully report on a minimum of 80% of patients in the group with a minimum of 30 patients between January and December 2009 (Medicare patients only).
- Successfully report on a minimum of 80% of patients in the group with a minimum of 15 patients between July and December 2009 (Medicare patients only).
NOTE: For reporting options that include a minimum 80% requirement, this means that providers must report successfully for at least 80% of their patients to which the measure applies in the given time period. Providers who choose to report on only 80% of their patient population for a certain measure must, therefore, report with complete accuracy. Because this would allow no room for error without losing the entire incentive payment, CMS recommends that providers report on more than 80% of their patient population for each measure whenever possible, even up to 100%.