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.
Anyone who knows even a little bit about behavior modification theory intuitively understands that offering rewards and/or punishments is an effective way to encourage people to do what you want them to do. The government clearly understands this principle and has been using incentives and penalties to motivate physicians to participate in its programs—PQRS, ePrescribing, and, most recently, the EHR incentives.
The EHR incentives have already prompted a great deal of EHR activity, but the program is too new to quantify cause and effect yet. A direct correlation between government policy and provider behavior, however, is evidenced by the history of my company’s ePrescribing license purchases, so I thought EMR Straight Talk readers would find the analysis of my company’s experience interesting.
As illustrated above, ePrescribing sales tracked the MIPPA legislation as follows:
2009 was the first year of ePrescribing bonuses, and the requirements (a 50% threshold) made it important to start ePrescribing early in the year. As you can see, this created a huge demand for ePrescribing licenses during the first half of 2009.
Sales continued in late 2009 and early 2010—although at a more moderate rate—as later adopters decided to take advantage of the last year of 2% bonuses and as the easier-to-meet threshold of 25 ePrescribing encounters was introduced.
Imminent penalties caused a spike in sales in the beginning of 2011, when providers first learned that 2012 penalties would be based on ePrescribing activity—or lack thereof—in the first 6 months of 2011.
Another interesting observation that can be made is that, for some providers, penalties are a much more effective behavior modification tool than incentives, regardless of the relative amounts of money at stake. My experience with ePrescribing—illustrated by the 2011 surge in licenses—was that many physicians who had not been persuaded by the 2% bonuses in 2009 and 2010 felt compelled to move ahead when faced with a 1% penalty for 2012. Regardless of whether a particular physician attributes more weight to the carrot or to the stick, the data above—although not unexpected—confirms the effectiveness of the government’s strategy.