Currently, there’s a common misconception among practice managers and healthcare providers that goes like this: “I’ve already attested to our CQM (Clinical Quality Measures) through Meaningful Use, so that means our PQRS reporting requirements have automatically been fulfilled too.” Not so. In fact, Meaningful Use and PQRS represent two separate incentive programs administered by the Centers for Medicare & Medicaid Services (CMS) and, as such, they have specific – and differing – rules and requirements. And, despite the fact that CMS administers both programs, each utilizes a different workflow, which means increased participation-related costs for most providers.
One of the primary differences between the two programs lies in how data is reported. For instance, for PQRS reporting, there are three primary ways to submit data:
- The claim method: G codes are submitted as zero-dollar charges (tedious and most error-prone method)
- The registry method: Data is submitted to an approved registry, which in turn submits the data to CMS
- The EHR method: Data is submitted directly to CMS by the EHR program
While the last option sounds like the most convenient option to many practice managers, be careful: Unless your EHR program has been approved by CMS, it cannot be used to provide data for PQRS reporting. That remains true even if the program is certified for use in Meaningful Use reporting.
How do you tell if your program is approved by the CMS? Check the CMS website for a list of currently approved vendors. What’s more, even if the EHR program you use is on the list, you still need to be sure the version you’re using is the version that has been approved. If not, you’ll need to upgrade to the CMS-approved version.
What’s more, the EHR method is not aligned with Stage 1 of Meaningful Use, which requires data to be submitted via a web portal at the CMS website. That means that even if your EHR vendor submitted data for your practice, CWMs still must be reported during the attestation process.
Also, because PQRS currently is limited to 51 CQMs, practice managers must be careful to ensure that at least three of those are also acceptable for Meaningful Use. Making it even trickier, the list of CQMs has different names and numbers for PQRS and NQS measures, which means practice managers have to be extremely careful and diligent about ensuring the correct names and numbers are used for each in order for the claims to be considered valid and successfully processed.
Fortunately, the powers-that-be at CMS understand the confusion and the extra time and cost burdens that have been created by having two separate and distinct reporting systems and requirements. During this year and into 2014, the agency is working to align the two incentive programs and their requirements to make reporting more straightforward and less cumbersome. The new process, which is being implemented as a pilot program with EHR vendors, should streamline the reporting process and help reduce the number of errors that can easily occur under the current sets of guidelines.