Effects of Fee Schedule on PQRI and ePrescribe

CMS recently released its calendar year (CY) 2011 Proposed Rule for the Medicare Physician Fee Schedule (MPFS). Comments to the Proposed Rule are due by August 24, 2010, with the final rule expected on or around November 1, 2010. The Proposed Rule is below...

Two areas which I feel are significant within this Proposed Rule are Physician Quality Reporting Initiative (PQRI) and the Electronic Prescribing (eRx) Incentive Program.

Physician Quality Reporting Initiative (PQRI)

The Proposed Rule would extend and modify the physician quality reporting initiative (PQRI), including several changes that were mandated under recent health care reform legislation. Under the Proposed Rule, CMS would:

• Add 20 individual PQRI measures, twelve of which would be available for reporting through electronic health records systems.
• Reduce the reporting sample requirements for claims-based reporting of individual measures to 50%.
• Create a new group practice reporting option that would allow participation by group practices with fewer than 200 EPs.
• Establish additional procedures for correcting unsatisfactory quality reporting, including interim feedback reports and an informal review process when CMS has determined that an EP did not satisfactorily submit PQRI data.
• Allow an additional 0.5% incentive payment to EPs who submit PQRI data and participate in a Maintenance of Certification program (including a practice assessment) as required by a recognized physician specialty organization for continued certification.
• Establish a new Physician Compare website.
• Integrate PQRI reporting with reporting elements that are established separately under regulations implementing the Electronic Health Record incentive program.

Electronic Prescribing (eRx) Incentive Program

CMS also proposed changes to the Electronic Prescribing incentive program. The Proposed Rule would:

• Establish a 10% incentive payment for successful e-prescribers in CY 2011.
• Exclude EPs who receive an incentive payment under the Medicare Electronic Health Records (EHR) Incentive Program from receiving a separate e-prescribing incentive payment. EPs who successfully participate in the EHR program could still be subject to a penalty in CY 2012 for not participating in the eRx program during CY 2011.
• Allow group practices with fewer than 200 members to participate in the eRx program.
• Establish criteria for penalizing EPs and group practices that do not successfully participate in the eRx program during CYs 2011 and 2012.