There has been a lot of chatter in the physician lounge recently about the “Pick your Pace” options for Medicare-related quality reporting next year. Of course, most of the chatter has been either from hospital administrators or from physician leaders of larger groups, since many smaller and independent physician groups may not even be aware of what is about to happen. I was part of a lively exchange this week around the fact that the program has to be budget neutral. To recap, the four options are: 1) Test the quality payment program (no penalty); 2) Report for part of the calendar year (small incentive); 3) Participate for the full year (modest incentive); and 4) Participate in an Advanced Alternative Payment Model (5-percent incentive). The devil may be in the details since it’s unclear how no penalty and small incentives can balance out to be budget neutral. Where is the incentive money going to come from?
It’s also not clear what the actual “test” process in option 1 is going to entail. Unless you’re just starting on your EHR journey, most organizations should be able to report for at least part of the year without significant difficulty. The data may not be of great quality, depending on how well you’re using your EHR, but you can still report it out. We’ll have to wait for the final rule, however, to see what the reporting requirements end up looking like. The partial-year option is going to be attractive to a great number of providers whose EHRs may not be ready for full-year reporting, so I expect to see the most questions on that option.
For providers that are in the thick of trying to comply with all the federal requirements, the 2015 Annual Quality Resource and Utilization Reports (QRURs) were released this week. The QRURs show what a provider’s payment adjustment will be for 2017 based on analysis of quality and cost domains. I attended the Medicare Learning Network call on the topic today. If I didn’t already know a considerable amount about the Value Modifier payment adjustment and the PQRS payment adjustment, I might be more confused after attending the call. The call began with a presenter essentially reading slides to the audience. There were constant references to the appendix, and fortunately the slides were available for download at the beginning of the call so that attendees could follow along.
I’m still mystified by the fact that it takes 21 months to analyze and release the data. We’re talking about using data from 2015 to determine how providers are paid in 2017. Although there was a Mid-Year QRUR that was released in the summer, it didn’t fully illustrate how payment adjustments might be applied. Regardless, the Mid-Year QRUR has little utility to encourage providers to modify their behavior in order to avoid adjustments, since it’s a look-back document. When trying to modify behavior, it’s most useful to provide real-time or at least fairly immediate feedback. Under the CMS construct, the feedback loop is delayed. Does it really take 21 months to aggregate and interpret the data? Or maybe the delay is intentional, as providers move deeper and deeper into a state of learned helplessness.
After about 15 minutes on the call, I felt my brain going numb as the presenter reviewed all the steps needed to access the QRUR. Providers or their designees have to go through the process of requesting an Enterprise Identity Management (EIDM) account which has multiple steps and sub-steps. The acronym soup became less savory as we learned about Provider Transaction Access Numbers (PTAN), which have to be obtained from the Medicare Administrative Contractor (MAC). Once you go through all the related steps and click your heels a couple of times, you can either view or download the presentation.
The presenter tagged-out to a second presenter who went through a table explaining the different sections of a “hypothetical” QRUR. Again, it was basically someone reading a slide to the audience – actually showing the various exhibits and sections while talking about them would have been useful. They did eventually go through some of the specifics, but I wonder how many attendees were following especially if this was the first time they were seeing this material. As the talk moved into discussion of the various quality and cost composite scores, and the need for a statistically significant deviation from the mean to be categorized as more (or less) than average, I wondered how many people attending the webinar understood those statistical terms.
Having spent my final two years at Big Medical Center working on a provider attribution project, I was eagerly awaiting the discussion of how Medicare beneficiaries were assigned to their respective Taxpayer Identification Numbers (TIN). This attribution drives the cost composite score found in the QRUR. Not only is CMS looking at spending per beneficiary, they are also looking at per capita costs for beneficiaries with various chronic conditions including diabetes, chronic obstructive pulmonary disease, coronary artery disease, and heart failure. They didn’t go into anywhere near the detail I expected for a provider to actually understand how the attribution was done. There are detailed elements involving whether a given TIN provided the majority of primary care services during the year, whether primary care services were received from subspecialists in the TIN, and more. None of that was covered.
Heading into the discussion of the “Informal Review Process” that providers can use to disagree with Value Modifier calculated for their TIN, the presenter became flustered due to a missing slide and rather than vamping her way through it, actually paused the presentation while they tried to sort it out. When she restarted, she actually re-read some scripted comments. I felt bad for her – we’ve all been on the downside of presentations that don’t go as planned. She then went into a discussion of various tables in the appendix, which again weren’t on the screen. Apparently, providers can download them in Excel and use them to analyze their own data, even de-identifying it by removing specific columns. It would have been good to see a screenshot of the data format to go along with the discussion.
Once she finally made it to the discussion of the review process, things were back on track. The review period began September 26 and is open for 60 days. The review has to be requested using the EIDM system and the process includes a Multi-Factor Authentication (MFA) step. Users have to remember to use the same MFA device type that they selected to use when they first created their accounts. Depending on how long ago one’s account was created, this may be a challenge. Users can then request the review, which leads to an additional three steps that weren’t shown in the webinar. Users can download a quick reference guide from the CMS website for more information on the reviews, although the link wasn’t shown in the webinar. As a side note, there were a couple of times at the beginning of the webinar where the speaker gave Web addresses verbally but with no link or text shown. Especially with a webinar platform, is there any reason why a link shouldn’t be shown on the screen and provided in the deck that was given to attendees? Another unusual statement (given by two different speakers) was that users should disable their popup blockers and should not connect wirelessly or via VPN but should connect via a wired connection. In this day of mobility and multi-platform device use, it felt like CMS is out of touch with how people use devices to receive information.
They opened the call to Questions and Answers and the first one seemed to challenge them, about whether the adjustment would be provided on a claim-by-claim basis or at the end of the year. Eventually they arrived at the per-claim answer. They answered the second question (about beneficiary attribution) by referring users to yet another website. I finally figured out why they wanted popup blockers disabled when a poll popped up asking how many people were viewing the session with me. There were also polling questions on whether I had difficulty accessing the webinar and whether I was satisfied with the webinar platform used. The questions continued, including one from a group who had discrepancies in the data from their QRUR. She was instructed to submit informal review for both QRUR and PQRS, and the latter has to be done through a different process that the group had difficulty explaining. They had to pause while they conferred, agreeing to look it up and provide it later.
That only served to underscore how complicated these programs are and how challenging it will be for provider groups of all sizes to try to keep up. Staying current with software and enforcing end-user behavior is hard enough, but this adds an entirely different layer of challenges for practice operations and management teams. I had to duck out for another call but am looking forward to seeing the rest of the Q&A in the transcript.
How is your organization coping with the QRUR? Email me.
Email Dr. Jayne.