When the calendar flipped to 2015, a number of changes occurred with Medicare’s Physician Quality Reporting System (PQRS) program, with the headline being the disappearance of incentive payments. The other changes will impact both diagnostic radiology and interventional radiology—though more so the latter than the former.
To help make sense of what’s new for 2015, Health Imaging reached out to Wendy Driscoll, MBA, senior client manager with ADVOCATE, a radiology billing company.
Health Imaging: What is the current status regarding incentives versus penalties with PQRS?
Wendy Driscoll: This is the first year that incentive payments have gone away. Back in 2013, the penalties started, but you had the opportunity to earn incentive payments at the same time. This year, the incentive payments are gone. Only the penalties remain and the penalties have increased.
What are the penalties and when are they assessed?
Participation in 2015 PQRS will impact Medicare payments you receive in 2017. So the PQRS penalties are 2 percent of your total Medicare payments. Then, in addition to that, there’s a value-based modifier program that is tied in with your PQRS participation. Your value-based modifier payments can be anywhere from a negative 4 percent up to a positive 4 percent, depending on your group size.
The breakdown for the group size is 10 or more physicians. So for example, if you just decided you were going to ignore the PQRS program altogether in 2015, and you’re in a group of 10 or more physicians, you would have a 6 percent penalty altogether—a 2 percent penalty for PQRS participation and then 4 percent on top of that for the value-based modifier program.
Are there any other big changes in 2015?
The biggest change would be the number of measures you are required to report on. In 2014, in order to avoid a penalty, you had to report on three PQRS measures, in 2015 you need to report on nine measures in order to avoid a penalty. In addition to that, one of those measures has to be what Medicare has deemed to be a cross-cutting measure. There are no true radiology cross-cutting measures, but there are some cross-cutting measures for the patient visit codes, the E&M codes. So if you’re a diagnostic radiologist and you do not see patients, no cross-cutting measures apply to you, but if you’re an IR [interventional radiology] physician that sees patients, then one of your measures has to be one of the PQRS measures related to patient visits.
Cross-cutting is something that Medicare has decided covers more than one Quality Domain—for example, community health and patient safety. Medicare publishes a table of the cross-cutting measures.
Any other differences between diagnostic and interventional radiology?
For diagnostic radiology, it doesn’t change that much from 2014. The biggest thing is going from three to nine measures. However, in order to get incentive payments for 2014, you had to report on nine measures anyway. Since there are actually less than nine measures that apply to diagnostic radiology, the 2015 changes should not impact diagnostic radiologists too much. Hopefully, diagnostic radiologists were reporting on everything they could report on anyway.
In addition to the patient visit PQRS measures mentioned earlier, the other big change for interventional radiology is that there were two measures in 2014 regarding osteoporosis that applied to kyphoplasties and vertebroplasties, as well as patient visits and evaluations for fractures. In 2015, while those measures are still around, they no longer apply to vertebroplasties or kyphoplasties. What that means for most IR physicians is that two of the measures that they could report on in the past are no longer an option.
IR really did see the majority of the 2015 changes.
Any other advice?
This year, with the increased requirements, groups might want to consider a registry now, just because there are some other measures that are available if you report by registry. That’s a change for 2015—before it was easy to say, “You should do claims-based reporting, there’s no benefit to registry.” But now, there are some additional PQRS measures reported through registry only, measures like breast biopsy procedures and cardiac stress tests, that may make registry options more worthwhile for radiologists to consider.
The biggest tip is start planning now for what you’re going to do for PQRS in 2015. Don’t wait too far into 2015 because you may find yourself scrambling. Develop a plan now if you’re thinking about one of the registry options. With the different registries, there are different time frames. For example, if you want to report as a group through a registry, you have to register by the summer. If you wait until the middle of the year, you may limit your options.