Registries Simplify Quality Reporting Mandates
Quality Feature — November 2014
Tex Med. 2014;110(11):57-62.
By Amy Lynn Sorrel
As federal quality reporting mandates and noncompliance penalties add up, experts say registries can help take the sting out of the process and rev up quality improvement for physician practices. The online reporting tool is also taking a front seat over claims-based reporting as Medicare signals its plans to eventually phase out that less efficient and less clinically accurate option.
It's like TurboTax for the Physician Quality Reporting System (PQRS), says Ariann Polasky, director of provider products for CECity. The company's PQRSwizard is one of two TMA-endorsed registries approved by Medicare.
Much like the tax preparation software that helps you submit income tax information to the Internal Revenue Service, registries take care of submitting physicians' quality data to the Centers for Medicare & Medicaid Services (CMS) on their behalf. Registries store and organize the clinical and billing data physicians collect from claims, web-based tools, practice management systems, or electronic health records (EHRs), and help manage the reporting process by providing guideposts and checks and balances along the way that steer physicians to successful submission.
And much like the tax code, federal quality reporting requirements get more and more complicated each year: For 2014, physicians can choose from nearly 300 individual measures and 25 measures groups, up from 179 in 2010.
Texas Medical Association leaders say claims reporting is okay when reporting on only a few measures and the claims information accurately represents the clinical situation.
But for physician practices with limited resources and time to adequately research the PQRS information every year, "it's getting too complicated to report via claims now," TMA Director of Clinical Advocacy Angelica Ybarra said. "Now that the quantity of measures has significantly increased, the varying codes associated with each measure increase, too. Measures specifications and reporting criteria can change from year to year, and if physicians don't stay on top of measure changes and track the new requirements, there's room for a lot of error."
Those mistakes are becoming more costly as the current financial incentives for participating in PQRS and other federal quality reporting programs shift to penalties for noncompliance. Once the new value-based payment system kicks in — by 2015 for larger practices and by 2017 for all physicians — Medicare will scale all payments based on practices' quality and cost performance.
Registry reporting not only promotes compliance in a growing number of quality programs but also puts physicians on the path to performance improvement, says TMA Council on Health Care Quality member Ronald Walters, MD. The Houston oncologist serves on the American Medical Association Physician Consortium for Performance Improvement and the hospital workgroup for the Measure Applications Partnership of the National Quality Forum.
Physicians may have to do some homework to choose the right registry. But the tools, "especially those created by your specialty society, have made the reporting more relevant to you, more applicable to you, and have worked their way into the process of being an approved mechanism for meeting different reporting requirements," he said. "We want physicians to get rewarded for the things they do well, that are most appropriate to the care they give their patients. And we want them to avoid penalties for the things that don't apply to their particular practice. And the registry helps gear that specifically toward your practice."
Out With Claims, In With Registries
This year, CMS has signaled at least a partial shift away from claims-based reporting by changes in measures groups reporting. The measures group mechanism allows physicians to fulfill their PQRS requirements by submitting annual data on 20 patients for a particular disease, such as diabetes. As of 2015, doctors can no longer do that via claims.
That's not to say claims-based reporting is a thing of the past just yet.
According to 2012 PQRS statistics, claims-based reporting was still the most popular method "and one that small physician practices depend upon," AMA told federal officials in an August comment letter on the 2015 Medicare Physician Fee Schedule. AMA also expressed concern the sudden elimination of measures groups from claims reporting could leave a significant gap in the measures portfolio of certain specialists and disproportionately affect physicians who are unable to participate through a registry or adopt certified EHR technology.
At organized medicine's urging, CMS has kept the claims-based reporting option for 2015. TMA and AMA continue to advocate for overall simplification of federal reporting requirements and elimination of yearly program changes that add administrative burden and cost.
Barring any major changes, however, registry reporting is becoming more important moving forward, particularly with implementation of the value-based payment modifier, Ms. Polasky says.
PQRS started out as a pay-for-reporting program, but the value-based system has transformed it into a pay-for-performance program. Whereas EHRs allow practices to report only on a limited subset of about 60 measures, registries offer more flexibility and allow reporting on several hundred, so practices can carefully choose and get graded on measures germane to their practice.
"So instead of just checking the box, those scores are more important. And registries have the capability to provide feedback and analysis tools to equip practices to improve over time on those scores prior to submission to CMS, so they can engage in quality improvement throughout the year," she said.
Reporting Made Simple
Every year, CMS updates PQRS, adding, removing, and modifying the measures on the list. Registry vendors sift through all of those legislative and regulatory updates and build them into their products.
Registries offer physicians an educational component in a user-friendly format, "so practices don't have to do all the research and take away time from patient care to keep up on the annual changes," Ms. Polasky said.
Registries do come with a cost. Physicians are responsible for regularly collecting their own clinical data — whether manually or through their own practice management or EHR systems — and pulling and inputting the patient information into the registry.
Depending on time and cost constraints, physicians can either input the information manually or pay for additional services to have their registry vendor upload it for them. And if you are using an EHR system, check with your vendor to find out if a registry function is compatible with your system.
But Ms. Ybarra says the thousands of dollars physicians could face in penalties for noncompliance far outweigh the nominal investment in a registry. TMA members receive a discount on the association's endorsed products, and because the registries stay up-to-date and simplify the process, "physicians don't have to deal with the complicated coding aspect of quality reporting. They simply answer questions on clinical data, and the registries assign the codes automatically and accurately."
Online forms provide information about each measure or measures group, with a list of corresponding code sets; as physicians enter their patient data, the registry helps ensure they are collecting the right information and reporting on the right measures, the right patients, and the right numbers.
For diabetes patients, for example, the registry will ask for patients' hemoglobin A1c measures. Predetermined fields ensure visit dates and diagnoses codes correspond with the measures criteria for that particular reporting period. Or if a measures group applies only to patients aged 18 to 75 but physicians enter data on an 80-year-old patient, the tool will signal an error by blocking them from inputting that information.
"If physicians are reporting another way, they may not have that level of checks and balances," Ms. Polasky said, adding that Medicare vets the registries to ensure they provide the required PQRS data elements, accurately calculate measures reporting and performance, and properly transmit the required information.
Better Accuracy, Fewer Penalties
The tools also help with reporting accuracy, she adds, reflected in the latest CMS data showing higher PQRS success rates via registry than via claims.
In 2012, 83 percent of eligible professionals satisfactorily reported at least one individual measure through claims, compared with 99 percent of registry participants and 98 percent of EHR participants. Incentive eligibility rates were highest (85 percent or higher) for registry and EHR reporting mechanisms, and group practice and accountable care organization web interfaces.
In contrast to claims reporting, registries give physicians the flexibility to report prospectively and retrospectively throughout the calendar year, says Melissa Blom. She is an account executive and PQRS subject matter expert for the TMA-endorsed Covisint PQRS registry.
Once physicians submit a claim, CMS does not allow them to go back and amend it with PQRS codes. So for physicians who haven't already started their 2014 reporting, TMA officials warn it's likely too late in the year to use the claims-reporting option to meet Medicare's 2014 reporting requirements by the Feb. 28 deadline. With a registry, on the other hand, doctors can go back and assess patients' records and report the data, so long as they submit the information by February. (Registry deadlines vary. Check with your vendor for details.)
That benefit also comes in handy now that CMS has upped some of its reporting requirements, Ms. Blom says. Physicians must report on either one or more measures group, for a 20-patient sample or on nine measures across three National Quality Strategy domains for 50 percent of patients to whom the measures apply.
"That's a lot of coding and potential for something to get overlooked and fall below the requirement. So if you mess up and discover it later in the year, you can't go back and fix something you missed [via claims]. Next thing you know, you've worked hard all year and failed in your reporting," she said.
From Reporting to Improving
Beyond compliance, registries can be the next step toward quality improvement.
Rather than getting a report a year-and-a-half later from CMS when it's too late to make any quality improvement changes, Ms. Polasky says registries help physicians put a system in place to track and monitor their total population and quality scores in real time.
Even if a practice reports on just 20 patients who meet a particular measure, the tool provides a snapshot of how many patients overall meet that criteria.
In some cases, practices might discover they are not doing something either their specialty or CMS has deemed important, she says. "On the other hand, maybe you are doing something, but you are only putting it in your notes. You never document it, and nobody knows about it, and you can never do queries to find out if your quality is good across patients because you don't have it stored in a discrete way."
Nor do such quality initiatives stop at federal programs, Dr. Walters says. The results of physicians' registry activities can also be used to comply with up-and-coming requirements for maintenance of certification or commercial insurers' quality improvement programs.
Amy Lynn Sorrel can be reached by telephone at (800) 880-1300, ext. 1392, or (512) 370-1392; by fax at (512) 370-1629; or by email.
No Turning Back
Henrietta family physician T. David Greer, MD, made the leap to a registry a couple of years ago as a guinea pig in one of the TMF Health Quality Institute's quality improvement projects. (See "Partner in Quality," October 2014 Texas Medicine, pages 43-48.)
Without an electronic health record system, the solo practitioner combines paper charting and electronic billing, "and I felt like the registry would give us a convenient way to do it [quality reporting] and not totally detract from patient time."
So far, the tool has delivered and made his practice more efficient at reporting on diabetes and hypertension measures.
With little time to sift through Medicare handbooks, Dr. Greer found the registry distilled his reporting requirements "into a 1-2-3-4 process of this is what you need to do and why you need to do it."
Meeting the requirements takes time. "I have to pay attention and have a nurse input the information, so it's still time consuming," he said.
But now Dr. Greer has a permanent record of ongoing performance he can refer to on demand. Already, he has pinpointed some areas of improvement. "One that stood out was the hemoglobin A1c measures for diabetes. We thought we were doing it on a timely basis, but according to the numbers, we weren't. And since then, we are much more consistent."
Registry Reporting Made Simple
Registries are simple, cost-effective online tools physicians can use to collect and report quality measure data under the Physician Quality Reporting System (PQRS) and avoid penalties for noncompliance.
Here's how to get started:
- Choose to report on either individual measures or a measures group that best reflects your practice, based on your specialty and patient population.
- Select a registry that can submit your measures to Medicare.
- Collect and enter your clinical and billing data. Your registry guides you through a series of questions for each patient, alerts you when you meet submission criteria, and offers a printable report of measure results.
- Review and submit your quality data, working with your vendor to ensure you report properly. Your registry vendor takes care of submitting your reports to Medicare on your behalf.
For information about member discounts for TMA's endorsed registries, visit TMA's PQRS Resource Center online or contact the TMA Knowledge Center at (800) 880-7955 or by email.
CMS-approved registries are online.
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