It’s a new year and new changes for Physician Quality Reporting System (PQRS) measures. There are some changes for 2015 that impact all eligible providers (EPs) as well as anesthesia providers. It is very important that every EP successfully participate in the PQRS program in 2015; failure to do so will mean a two percent reduction in their Medicare payments in 2017.
The program this year will continue to require reporting nine measures in three domains to meet the satisfactory reporting criteria via claims and registry if the EPs report on one to eight measures, as applicable, to EP practice. If an eligible professional reports on one to eight measures, that EP would be subject to the MAV process. In the past, anesthesia has not had the required number of measures to report, but a cluster was developed so that the specialty would be able to report and not be subject to the MAV process. If only one measure applies to your practice, that is still all that you need to report in 2015 in order to avoid the two percent penalty in 2017. For a measure to count, you must report it in at least 50 percent of your eligible cases.
Anesthesia care continues to have a cluster, but there are now only two measures to report. Measure #30, Antibiotic Prophylaxis, has been retired for 2015 and will no longer be reported. CMS indicated that EPs consistently met the performance rate (close to 100%), suggesting no gap in care, allowing CMS to delete the measure. The two remaining measures are measure # 76 –Prevention of Central Venous Catheter (CVC) – Related Bloodstream Infections; and measure # 193 – Perioperative Temperature Management. If only measure 76 is reported, an EP would not be subject to MAV. But, measure 193 is reported far more frequently so, with only one measure being reported that would meet the threshold for numerator, it is a certainty the anesthesia providers’ claims will go thru the MAV process. Both measures have been revised and updated this year.
The changes to measure #76 are:
- Updated Title, Description, Numerator Statement, Numerator Definition (Maximal Sterile Barrier Technique), Numerator Option Description, and Clinical Recommendation Statements
- Added Numerator Definition (Sterile Ultrasound Techniques)
Measure #193 also has a few updates:
- Updated Numerator Option Descriptions
- Deleted Numerator Note
- Deleted from Denominator Coding: CPT Codes 00452, 00622, 00634
- Deleted from Numerator Coding: CPT II Code 4256F
- Added to Numerator Coding: G Codes G9362, G9363
For 2015, some other basic PQRS measures may be applicable to anesthesiology:
- Measure #44 – Continued Administration of Beta Blockers to Cardiac Surgery Patients
- Measure #130 – Documentation of Current Medications in the Medical Record
- Measure #226 – Preventive Care and Screening: Tobacco use – Screening and Cessation Intervention
- Measure #342 – Pain Brought Under Control Within 48 Hours
- Measure #358 – Preoperative Patient Risk Assessment Using a Validated Tool
A new requirement in 2015 is that at least one of your measures must be a “cross-cutting” measure. In the Proposed Rule, CMS introduced the idea of “cross-cutting” measures in order to “help bring alignment with respect to a set of measures all eligible professionals may report.” If the EP has seen at least one Medicare patient in a face-to-face encounter during 2015, the EP must report on at least one of the 19 measures contained in the list of cross-cutting measures.
Every EP in an anesthesia or pain practice should make sure to report, for at least 50 percent of the patients seen in a face-to-face encounter, at least one of the following PQRS measures. Until now, it has not been necessary for anesthesiologists to report on any of these “cross-cutting” measures in order to avoid the PQRS penalty. Because of this change, the records given to billers and coders may need to be updated so that the new measures can be captured on the EP’s Medicare claims.
CMS states, “In the instance where an eligible professional may not have at least nine measures applicable to his/her practice, the eligible professional would still be required to report at least one cross-cutting measure, if applicable.” The MAV process will allow CMS to determine whether a group practice should have reported on any of the 19 crosscutting measures. The “cross-cutting” measures recommended for anesthesiology are:
- Measure #47 – Advance Care Plan
- Measure #128 – Body Mass Index Screening and Follow-Up
- Measure #130 – Documentation of Current Medications in the Medical Record
- Measure #226 – Tobacco Use Screening and Cessation Intervention
- Measure #317 – Screening for High Blood Pressure and Follow-Up Documented
One point to remember for all physicians related to the annual release of the Medicare Physician Fee Schedule is the updated PQRS guidelines, especially since 2013 when the program began penalizing unsuccessful reporters. Successful PQRS submission for 2015 will allow eligible providers to avoid a two percent payment adjustment in 2017. Incentive payments are no longer available for PQRS.