CMS Releases PQRS and VM Reports
Physicians who want to contest potential payment penalties associated with the 2018 Physician Quality Reporting System (PQRS) and/or the Value Modifier (VM) have until Dec. 1, 2017, to request an informal review of their data. The penalties in question stem from policies in effect prior to enactment of the Medicare Access and CHIP Reauthorization Act (MACRA). However, CMS has proposed some revisions intended to lessen the impact of prior policies and has based its calculation of related payment adjustments on these more lenient proposals.
Revisions in the prior VM and PQRS policies were laid out in the 2018 Medicare Physician Fee Schedule proposed rule issued last summer, and came about as the result of advocacy from the AMA and other medical organizations. They will reduce the number of PQRS and VM penalties as well as the severity of VM penalties that would otherwise have occurred in 2018 based on performance in 2016.
If the proposals are finalized, a 2 percent PQRS penalty and a VM penalty could be avoided by having reported six measures in 2016, rather than complying with the previous reporting requirements of nine measures that crossed at least three domains and included one cross-cutting measure. The proposal would also halve VM penalties and bonuses, with penalties falling from a maximum of 4 percent to 2 percent for groups of 10 or more and from a maximum of 2 percent to 1 percent for smaller practices. In the unexpected event that these more lenient policies are overturned in the final Fee Schedule rule, penalties will be recalculated based on the prior policies.
Physicians can determine whether they will be subject to PQRS and/or VM adjustments on their 2018 Medicare fee-for-service claims by examining their 2016 PQRS feedback reports for PQRS adjustments and their 2016 Quality and Resource Use Reports (QRURs) for VM adjustments. They will also receive letters stating whether they will or will not receive a 2 percent PQRS penalty in 2018. CMS has no plans to send a separate letter about the VM. Therefore, the AMA highly encourages practices to download and review their QRURs and PQRS feedback reports to determine whether they are subject to potential PQRS and/or VM payment adjustments and ensure that such adjustments are based on the reduced requirements and penalties before filing for an Informal Review with CMS.
Those who have questions, even if they are uncertain about penalty status, are urged to submit a request for an informal review. CMS has said that it cannot guarantee that filing for an informal review in either PQRS or VM will automatically trigger an informal review in the other. Therefore, the safest course is to file requests for review of both PQRS and VM data.
Filing an informal review and/or accessing PQRS reports and QRURs requires an Enterprise Identify Management Account (EIDM) with the appropriate role. Consequently, it will also be necessary to determine whether someone within the practice has such an account and to set one up if it does not already exist.
CMS offers information on how to obtain a QRUR and request a PQRS Informal Review.
If you have not already done so, 2016 PQRS feedback reports can be accessed on the CMS Enterprise Portal using an Enterprise Identity Management (EIDM) account. See PQRS Analysis and Payment webpage for more information.
For additional questions regarding the informal review process, contact the QualityNet Help Desk at 866-288-8912 (TTY 877-715-6222) or Qnetsupport@hcqis.org. The help desk takes calls Monday–Friday, 7 a.m.–7 p.m. CDT. To avoid security violations, do not include personal identifying information, such as Social Security Number or TIN, in email inquiries to the QualityNet Help Desk.
For information on how to file a VM Informal Review, see the 2018 Value Modifier Informal Review Request Quick Reference Guide.
To review your QRUR, see the 2016 QRUR and 2018 Value Modifier webpage. CMS is also hosting a call to discuss these reports Oct. 19, 1:30 p.m. EDT. Register.
For additional questions regarding EIDM, contact the QualityNet Help Desk at firstname.lastname@example.org or 866-288-8912 (TTY 877-715- 6222); For QRURs or the Value Modifier, contact the Physician Value Help Desk at email@example.com or 888-734-6433 (select option 3).