Physician Quality Reporting For 2013 and Beyond

The 2010 Patient Protection and Affordable Care Act(the "ACA") impacts a number of industries and professions, including healthcare practitioners, insurance companies, employers, and individuals. Recently, for example, problems with the Health Insurance Marketplace website have dominated the headlines.

Flying under the media's radar is the ACA's new requirements for physicians to report under the "Physician Quality Reporting System"("PQRS"), which, prior to the ACA, was called the Physician Quality Reporting Initiative ("PQRI"). Under PQRS, there are incentives and penalties placed on physicians' reporting of quality data. Practitioners who see Medicare Part B patients and who are reimbursed under the Medicare Physician Fee Schedule ("PFS") are eligible for participation in PQRS.

Incentives

To encourage full reporting in 2013 and 2014, PQRS allows for a +0.5% adjustment of the physician's Medicare reimbursements. This reimbursement incentive applies in 2013 and 2014 with respect to data collected in those same years.

Penalties

After 2014, PQRS imposes a penalty of either -1.5%(in 2015) or -2.0% (in 2016 and beyond) for failure to meet one of the three options listed below. The reimbursement penalty applies two years after each reporting period. For example, if a physician does not comply with the 2013 reporting requirement, then the physician will be penalized with a -1.5% reimbursement adjustment in 2015.

Avoiding 2015 Penalties

Generally, three options are available for individual professionals to avoid 2015 penalties: (1) meet the 2013 PQRS reporting requirements, which will not only avoid a penalty but also will qualify for the 2013 incentive payment; (2) report on at least one quality measure; or (3) elect to participate in administrative claims-based reporting. October 18, 2013, was the deadline to register with CMS for administrative claims-based reporting, however options 1 and 2 are still available. Note that the group practice reporting option ("GPRO") requirements are similar but not identical to those listed above.

The Centers for Medicare and Medicaid Services ("CMS") maintains a number of guides that may be found through the CMS website, and our team is available to help.