Recently, Thomas Valuck and Terry Kay, of CMS, held a briefing on the Tax Relief & Health Care Act provisions on quality reporting for 2007 and 2008. The information given was based on the statutes in the Act, and included:
Consensus-based quality measures During the period beginning July 1 and ending Dec. 31, 2007, the quality measures to be used are the 66 measures under the Physician Voluntary Reporting Program. Any changes must be based on the results of a consensus process in January and published on the CMS Web site by April 1.
Valuck noted that a consensus process is not CMS holding a regulatory meeting about quality measures. A consensus process has to be like AQA or National Quality Forum (NQF). CMS has asked AQA to expand its umbrella to bring in all eligible professionals, including non-physicians. The AQA held its meeting Jan. 22.
Anders Gilberg of the American Medical Association (AMA) said the Physician Consortium plans to give its final measures to AQA by the Jan. 22 meeting. Valuck said the AMA’s Physician Consortium has offered its copyrighted measures to non-physicians. The consortium also has agreed to consider evidence of groups not currently covered. Valuck encouraged those who don’t have quality measures to get in touch with the Physician Consortium, AQA and NQF.
Quality measures for 2008 will go through a rulemaking process with a proposed rule no later than Aug. 15 and will address the use of medical registries. The measures have to be endorsed or adopted by a consensus organization such as AQA or NQF. The measures do not have to be fully developed before submitting to the organizations, but the submitter must be able to prove the measure is valid, according to Valuck. Michael Rapp is the coordinator for investigating the registries.
Identification Units For 2007, CMS will use the taxpayer identification number as the billing unit, but it has not made any decision on what ID to use for analysis – individual or group level. Using the individual level or group level could create a muddle, according to Valuck.
Quality reporting If no more than three quality measures are indicated, the physician chooses only the ones that are applicable to his services. If four or more measures are applicable, then the physician reports on at least three measures. In addition, physicians must report the measures on at least 80 percent of the cases to be eligible for the bonus. The physician determines which measures to use. CMS will validate (i.e, through sampling) whether the applicable measures have been reported. In other words, if a physician only reports on one or two measures when three measures were applicable, CMS will deny the bonus payment. The sampling validation will not be open to the review process but must have some form of due process.
Bonus Payment Calculating the bonus payment appears to be one of the more confusing provisions on quality reporting. The bonus is 1.5 percent based on the allowed charges for covered services under the physician fee schedule furnished during the reporting period (July-December). Claims must be submitted no later than two months (by Feb. 28) after the end of the reporting period. Physicians would receive a lump sum payment in 2008. Note: The Health Professional Shortage Area (HPSA) bonus will not be part of the calculation.
Bonus Cap The Tax Relief & Health Care Act limits the bonus payment. Calculating the bonus cap appears to be one of the more confusing provisions on quality reporting. There are three components to the bonus cap. 1.) Average per measure payment amount; 2.) 300 percent of the average per measure payment amount; 3.) the number of instances the measures are reported. The cap will be a product of the total number of quality measures reported by the provider and 300 percent of the average per measure payment amount.
The average per measure payment amount is equal to the total number of allowed charges for all covered services furnished during the reporting period on claims for which quality measures are reported; divided by the total number of quality measures for which data are reported during the reporting period.
Physician Assistance & Quality Initiative Fund Congress allotted $1.35 billion for the fund. Valuck said the intent for the fund is still under consideration. Valuck speculated that the money may be used to fund the payment update next year if Congress acts to fix it.
The agency anticipates many inquiries about the quality reporting program and expects to release FAQs in the near future. The current PVRP measures are available on the CMS web site at http://www.cms.hhs.gov/PVRP/. Any changes will be published
