The Apparently Sorry State of Radiology and PQRS – Failure in 2015 Means Payment Penalties in 2017

First I want to apologize for the title – but it seems too true for me to describe it any other way.  This should not have happened.  It is not for the lack of trying by the ACR. Some will blame CMS or the government.  How can I say this – Balderdash!  For all the radiology groups out there let me ask you this:  Are you submitting 9 PQRS quality measures for 2015?  If not, why not?  This should not be a surprise.

Over the past few months of speaking with many people in the industry I’ve come to the conclusion that, unfortunately,  90+ percent of radiology groups are unlikely to submit PQRS data for the required 9 quality measures.  Many thought the target was still 3 measures.  Unfortunately, for those not submitting  measures their Medicare payments will be reduced by at least 2% in 2017 (and quite possibly more).  I estimate that this will result in a penalty of ±$2,500 per rad in 2017.

At this point, for all practical purposes it is too late to do anything about it – you’re either preparing to submit 9 PQRS measures in the next few days or you’re not.  Having said that, our group successfully reported 9 measures in 2015 and will do so again in 2016.

How did we do it?  First, we chose to enroll in the ACR’s National Radiology Data Registry 3 years ago and started submitting data to the Dose Index Registry.  Second, and more importantly, we had the foresight to enroll in the ACR’s Qualified Clinical Data Registry (QCDR) in mid-2015 which gave us access to several other PQRS measures beyond the original claims-base measures.  For example, the QCDR allowed us to meet measures related to turn-around time for CT, MRI, NucMed, US, X-ray, and PET, each of which is a separate measure.  The QCDR also allowed us to report several mammography related measures, a catheter-related infection measure, and, because we also participate in the ACR’s Dose Index Registry and CT Colonography measures we had several other measures available to us in these areas.  Frankly, if we were still using the claims based registry we had used up until mid-year none of our radiologists would have qualified.

My point here is not to worry or cause you to get upset if you are not submitting at least 9 PQRS measures for last year.  That is over and done.  My purpose today is to alert you to the need to take steps very quickly so you can prepare to meet the PQRS reporting requirements for 2016 and avoid the 2018 penalties.  I recommend Radiology practices:

  1. Enroll in the ACR’s Qualified Clinical Data Registry;
  2. Enroll their group and facilities in the ACR’s National Radiology Data Registry (NRDR) and submit data to virtually every NRDR registry, including the Dose Index Registry, National Mammography Database Registry, Lung Cancer Screening Registry, CT Colonography Registry, and the General Radiology Improvement Registry.

These registries provide opportunities for measures unavailable on the standard claims based PQRS registries, and, absent participation in a Shared Savings Plan Medicare ACO, represent the most viable process for meeting the required number of measures next year.

I don’t want to mislead anyone that the doing the above is easy or that by merely enrolling with automatically qualify you.  It isn’t and it won’t.  Successfully meeting the 2016 PQRS requirements will require support from whomever is doing your billing and cooperation from your facilities.  Count yourself lucky if you have a single hospital system on the same infrastructure.  It gets more complicated the more discrete facilities you have to involve.  In addition to your facility’s cooperation you will also likely have to develop some internal skill sets (or your billing company will) and/or identify where you need external support and get it.  Simply enrolling is the easier part.  The hard part is getting at the information you need to compile and getting it in the proper format and structure.  It will take a concerted effort beginning soon if you want to turn this around for 2016.  Don’t delay.

The PQRS program is still changing.  For example, there will be a Group Reporting Option available soon at the ACR (commonly referred to as a GPRO).  The current process is performed at the individual radiologist level.  Today, it is entirely possible you could qualify some, but not all of your practicing physicians.  In a GPRO, the entire group is counted as a single entity.  We intend to go the GPRO route in the future, and I recommend you explore that option.  There may be some for whom individual reporting still makes sense, but for most groups the group option should be the better choice.  It should be available through the ACR soon.

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  1.  The penalty could go up to 4% or so if your group reports no measures.
  2. There is a very small group of radiologists whose practice is so narrow that they could use the MAV process to prove that it would have been impossible for them to meet 9 measures.  For example, if a radiologist’s practice is limited to mammography and never (and I mean never) performs fluoroscopy procedures, it would be impossible to report Fluoroscopy times.  The MAV process would allow the mammographer radiologist to not have to meet measures impossible for them to meet.  However, even if a radiologist performed 1 fluoro procedure in 2015 they would have to report on that measure.  In short, most radiologists reading this email will not be able to use the MAV process to get around the penalty.

 

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