Authors: Christina Hielsberg, M.A.; Matthew T. Popovich, Ph.D.
ASA Monitor 03 2016, Vol.80, 36-37.
It has long been speculated that the Centers for Medicare & Medicaid Services (CMS) would move toward phasing out the claims-based reporting mechanism for reporting PQRS measure data. The removal of this mechanism for most of the 2016 anesthesia care measures turns this speculation into reality for many physician anesthesiologists. But as members face this time of transition, there are several other valid reporting mechanisms that you can explore to satisfactorily report PQRS this year.
Moving from the claims-based reporting mechanism to another mechanism may cause you some anxiety – trying to understand different reporting requirements, contracting with a vendor or registry and determining how to operationalize quality capture in your practice can seem like daunting tasks. ASA has provided resources both online and in previous articles to help explain the different PQRS reporting solutions available to you. ASA recommends anesthesiologists and pain medicine doctors review the reporting mechanisms and choose the one that best fits their practice.
In previous years, the Anesthesia Quality Institute (AQI) had been a “traditional” qualified registry (2011-14). The traditional qualified registry differs from the Qualified Clinical Data Registry (QCDR) reporting mechanism, which ASA has offered through the AQI National Anesthesia Clinical Outcomes Registry (NACOR) since 2014. ASA and AQI have submitted applications to CMS to be both a qualified registry and a QCDR for 2016. While on the surface these two mechanisms appear to be similar, there are distinct differences in terms of reporting requirements for each.
What Is a PQRS Traditional Qualified Registry?
Generally referred to as a “traditional” qualified registry, PQRS qualified registries (QRs) were introduced to the PQRS program in 2008. QRs are only capable of reporting on the PQRS approved measures. A QR will submit data on behalf of eligible professionals (EPs) and group practices. QRs provide an easy alternate solution to reporting PQRS data to CMS and are ideal for EPs who wish to simply satisfy PQRS reporting requirements. We expect CMS to release a list of 2016 qualified registries during the first quarter of this year.
What Is a PQRS Qualified Clinical Data Registry?
A qualified clinical data registry, or QCDR, is a CMS-approved entity that collects medical and/or clinical data for the purpose of patient and disease tracking to foster improvement in the quality of care provided to patients. A QCDR is different from a qualified registry in that reporting is not limited to measures within PQRS. For 2016, QCDRs have the ability to include up to 30 additional non-PQRS specialty specific measures. This means physician anesthesiologists have the ability to select measures that may be more meaningful to their practice.
How Does a Traditional QR Differ From a QCDR?
While the submission of data to QRs and QCDRs is relatively similar, reporting requirements differ between the two. The biggest distinction lies in that reporting via QCDR requires the collection and submission of outcome measures and data on Medicare and non-Medicare patients. For physician anesthesiologists who do not have outcomes data or do not have the ability to collect outcomes data, the traditional qualified registry may be a good option for fulfilling 2016 reporting requirements.
Data Submission via QRs and QCDRs
QR and QCDR vendors, including ASA and AQI, will provide you specific instructions on how and when to submit data for the selected measures you choose to report. Typically, QCDRs will require the submission of data via an XML file format. QRs in the past have accepted data in a couple of different ways. EPs have been able to use an online portal for manual entry of data or submit a template (e.g., XML, Excel file) for data upload into the QR. It is the responsibility of the individual EPs and/or practices to ensure that the QCDR or QR is receiving all required data. Furthermore, any adjustments to collecting such data remains under the purview and responsibility of the individual EP and the practice.
Once CMS publishes the list of QRs and QCDRs, it is important for EPs to review the measures that the QR/QCDR vendor has the capacity to report, to ensure reporting requirements can be satisfied. Remember, because of the PQRS reporting criteria (reporting on either 50 percent of your Medicare Part B Fee-For-Service for the qualified registry reporting mechanism or 50 percent of all eligible patients for the QCDR reporting mechanism), practices should have sufficient time to operationalize their capture forms and processes for 2016 PQRS reporting.
Additional guidance on the 2016 PQRS program is available athttp://www.asahq.org/quality-and-practice-management/quality-improvement/physician-quality-reporting-system.