Maintenance of Certification:PQRS Update!

So let me share what I’ve discovered so far from the Centers for Medicare and Medicaid Services (CMS) QualityNet Help Desk 866-288-8912. I really appreciate Sandy Nelson’s help from the Iowa Medical Society (IMS). Incidentally, a useful link for physicians to have is http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/Downloads/2014_MOCP_IncentiveMadeSimple_Final11-15-2013.pdf

To make a very long story short, for me and other physicians who are members of Accountable Care Organizations (ACOS) the Maintenance of Certification:Physician Quality Reporting System (MOC:PQRS) doesn’t mean a great deal. However, this is not just about me and it’s not just about ACOs. It’s about the impact that MOC:PQRS could have on the livelihood of all physicians.

Physicians who are not part of an ACO may be responsible for participating in the MOC:PQRS. This is problematic because I doubt most physicians know about it. My top administrator knew that the PQRS existed, but not much beyond that. I talked to two people at The CMS QualityNet Help Desk (one yesterday and another this morning). This morning’s contact told me that CMS had been “bombarding” physicians for years about this program, and thought everyone knew about it. She even told me that I’m the only physician who has ever asked her about the MOC:PQRS.

Did the IMS and the Iowa Psychiatric Society (IPS) already know about this program? If they did, then they probably already know that the MOC:PQRS carrot and stick program turns into a stick at the end of this year, when the 0.5% incentive ends and a penalty of 1.5% of a private practice physician’s total Medicare billings will be assessed as of 2015, up to 2.0% starting in 2016. If you weren’t participating last year, you could be liable for penalties. I think there’s still time to enroll and participate, but the deadline is the end of next month, I believe.

CMS deemphasizes the stick part of this program, but it’s written into the Affordable Care Act (ACA).

CMS, in conjunction with the Affordable Care Act (ACA) law, created the PQRI (now called PQRS) financial incentives to physicians who participate in Maintenance of Certification (MOC). In connection with that, beginning in 2014, “physicians who do not submit measures to PQRI will have their Medicare payments reduced.” This is taken directly from a condensed version of the ACA, http://www.dpc.senate.gov/healthreformbill/healthbill53.pdf .  It’s on page 23 of the pdf document under TITLE III—IMPROVING THE QUALITY AND EFFICIENCY OF HEALTH CARE: Subtitle A—Transforming the Health Care Delivery System: Part I – Linking Payment to Quality Outcomes under the Medicare Program, Sec. 3002. In its entirety:

“Improvements to the physician quality reporting initiative. Extends through 2014 payments under the PQRI program, which provide incentives to physicians who report quality data to Medicare. Creates appeals and feedback processes for participating professionals in PQRI. Establishes a participation pathway for physicians completing a qualified Maintenance of Certification program with their specialty board of medicine. Beginning in 2014, physicians who do not submit measures to PQRI will have their Medicare payments reduced (italics mine). Section 10327 provides an additional 0.5 percent Medicare payment bonus to physicians who successfully report quality measures to CMS via the new Maintenance of Certification program and eliminates the MA Regional Plan Stabilization Fund.”

The QualityNet help Desk (the Iowa contact is in Des Moines) is really not a part of CMS per se, but contracts with CMS. The representative I talked to from the help desk told me that the MOC:PQRS is totally voluntary.

Well, it’s anything but voluntary when the incentive disappears and the penalties are imposed. It turns out the only way for private practice physicians to avoid the penalties is to register as individual physicians with the MOC:PQRS and deliver quality measure reports. My contact here at The University of Iowa Hospitals and Clinics tells me the link to find out how to do that is http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/MeasuresCodes.html

Open the Implementation Guide link and see two documents. One contains the measures. For ACO Group Practice Reporting Options (GPRO), our compliance office people report on the Patient Safety Measure Medication reconciliation, which may or may not involve psychiatric patients.

On the other hand, for individual practitioners, there are quality measures for Major Depressive Disorder (MDD), on pages 13,14; documentation of current medications on page 17; use of high-risk medications in the elderly on page 28; substance use on page 30; dementia on pages 35, 36; and for depression on pages 50, 51.

I’m betting that most Iowa physicians didn’t know about this. It’s hard for me not to imagine that CMS has a conflict of interest in this matter because it leads to less money going out from CMS to physicians. However, I’m also told that this program is supposed to be budget-neutral.

And to reiterate, the American Board of Psychiatry and Neurology (ABPN) has partnered with the American Board of Medical Specialties (ABMS) and the CMS to promote this process. See link http://www.abpn.com/forms.html#moc  and http://www.abpn.com/downloads/moc/MOC_Template_letter_diplomates_MOCMatters.pdf

I think this provides another reason to oppose Maintenance of Licensure (MOL) in Iowa. The complexity associated with MOC alone is byzantine, and I’m increasingly persuaded that it’s difficult to challenge MOL without also challenging the legitimacy of MOC. Indeed, several states are already doing this. We need less complexity in regulation, not more.

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Comments

  1. Appalling. There is only 1 way to steer clear of the PQRS mess, and that’s to not accept medicare. Good luck with that for most practicing physicians.
    Check out this month’s Carlat Report: http://www.thecarlatreport.com/issue/vol12-no1
    Ethics in Psychiatry
    The first article (yeh, I wrote it), is about the ACA, including the PQRS debacle.

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