Kudos to CMS for making good on its promise to align quality measure reporting and incentives across the various government programs with which physicians must contend. With the publication last week of the 2013 Medicare Professional Fee Schedule final rule, CMS delivered on the harmonization promised in the Meaningful Use Stage 2 final rule in August.
This is very good news for physicians. Without the compromises that CMS made in both rules, physicians would be confronted with the challenge of trying to participate in a minimum of 3 government programs that involve quality measure reporting—ePrescribing under MIPPA, meaningful use under ARRA, and PQRS—each with its own set of intricate requirements, timetables, populations on which to report, reporting mechanisms, and incentive/penalty schedules. Not only would this be incredibly complicated, but it could give rise to incongruous situations in which a physician might, for example, successfully ePrescribe as part of demonstrating meaningful use, and yet still be subject to a penalty for inadequately ePrescribing under MIPPA.
Among the key areas of alignment are the following:
- Reporting for PQRS using the EHR reporting option (as opposed to claims or registry reporting) will satisfy the clinical-quality-measure-reporting component of meaningful use. PQRS EHR-based measures will be aligned with the measures available for reporting under the EHR incentive program.
- Meaningful use clinical-quality-measure reporting via PQRS will only be on Medicare patients, while all other meaningful use measures will continue to apply to all patients, regardless of payer.
- PQRS reporting will be done using the CEHRT (Certified EHR Technology) that is required for meaningful use, eliminating the current requirement to use a separately certified “PQRS-Qualified” system.
- Successful ePrescribing under meaningful use will protect physicians from ePrescribing penalties under MIPPA.
The government programs remain complex—but there is no question that aligning them as the recent rules do will decrease the reporting burden on physicians, spare related administrative costs, and eliminate the costs associated with duplicate EHR certification requirements. Valuable physician resources will be better allocated to providing the quality of care these programs seek to measure.