PQRS/EHR incentive pilot program

ByJeff Grant

by Jeff Grant

This article was published as part of a blog series on electronic health records and the optometric practice.

In January, a little-known change to the EHR incentive attestation portal was introduced and is causing grief for some eye care practitioners who are attesting. This change already has some of my clients scrambling because they clicked "yes" without really knowing what they were agreeing to.

The change introduced is an invitation to participate in the Physician Quality Reporting System-Medicare EHR Incentive Pilot. Beginning in 2012, eligible professionals may satisfy the meaningful use objective to report clinical quality measures (CQMs) to the U.S. Centers for Medicare and Medicaid Services (CMS) by reporting them through:

Medicare and Medicaid EHR Incentive Programs’ web-based Registration and Attestation System or
participation in the Physician Quality Reporting System-Medicare EHR Incentive Pilot, which utilizes the 2012 Physician Quality Reporting System EHR Measure Specifications.

You will be able to satisfy the meaningful use objective to report CQMs to CMS by reporting them through:

Medicare and Medicaid EHR Incentive Programs’ web-based Registration and Attestation System (as has been the case since the beginning of the EHR incentive program) or
participation in the Physician Quality Reporting System-Medicare EHR Incentive Pilot, which utilizes the 2012 Physician Quality Reporting System EHR Measure Specifications.

While the intent of the project is very good – trying to align PQRS quality reporting with EHR incentive quality reporting and to simplify the process – the details might cause you some problems. The problems come from the possibility that you are not eligible or that your EHR vendor cannot meet the needs of the pilot.

If you have no patients in the denominator of the three core measures and the three alternate core measures as well as any of the remaining 38 measures, you are not permitted to participate in the Physician Quality Reporting System-Medicare EHR Incentive Pilot.

Eligible professionals must electronically report CQM results via one of the following methods:

Use a Physician Quality Reporting-qualified EHR Data Submission Vendor to submit calculated/aggregate CQM results (in an XML file) from the eligible professional’s Office of National Coordinator (ONC)-certified EHR to CMS on the eligible professional’s behalf (required to satisfy the CQM requirements for the EHR Incentive Program), and submit the same CQM data at an individual patient level (in the Quality Reporting Data Architecture [QRDA] Category 1 format) using data from the eligible professional’s Physician Quality Reporting-qualified EHR system (required to satisfy the PQRS requirements).
Direct EHR-based reporting. The eligible professional submits CQM data at an individual patient level directly from an ONC-certified, Physician Quality Reporting-qualified EHR system in the QRDA Category 1 format (required to satisfy the CQM requirements for the EHR Incentive Program and qualify for a PQRS incentive). CMS will then calculate CQM results using a uniform calculation process.

Chances are good that you will not be eligible (due to CQMs with denominators or zero) and/or that your EHR vendor cannot meet the requirements for data submission. So, be careful when you attest that you do not opt in to this pilot unless you know that you and your EHR vendor qualify.