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AdvantEdge Healthcare Solutions 2014 Physician Quality Reporting System (PQRS) Resource Guide 2/13/2014

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Page 1: AdvantEdge Healthcare Solutions 2014 Physician Quality … · 4 2014 PQRS REPORTING OPTIONS Reporting Periods In 2014, there is only one reporting period of 12 months except for the

AdvantEdge Healthcare Solutions

2014 Physician Quality Reporting System (PQRS) Resource Guide

2/13/2014

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AdvantEdge Healthcare Solutions

2013 Physician Quality Reporting System (PQRS)

January 29, 2014 __________________________________________________________________________________

We have created this PQRS Resource Guide so that the most pertinent PQRS information for 2014 can be

found in one document. Links have been provided for you to access the more detailed information

provided on the CMS website.

Table of Contents

ELIGIBLE PROFESSIONALS (Providers) (EPs) ....................................................................................... 3

2014 PQRI BASICS ..................................................................................................................................... 3

2014 PQRS REPORTING OPTIONS .......................................................................................................... 4

Reporting as an Individual EP ...................................................................................................................... 5

A. INDIVIDUAL QUALITY MEASURES REPORTING..................................................................... 5

B. “MEASURES GROUPS” REPORTING ............................................................................................. 6

C. QUALIFIED CLINICAL DATA REGISTRY – New for 2014 .......................................................... 7

Reporting as a Group Practice ...................................................................................................................... 8

A. GROUP PRACTICE REPORTING (GPRO) ..................................................................................... 8

B. Certified Survey Vendor - New for 2014 ......................................................................................... 12

2014 REPORTING MECHANISMS .......................................................................................................... 13

A. CLAIMS-BASED REPORTING ...................................................................................................... 13

B. REGISTRY REPORTING ................................................................................................................ 13

C. EHR REPORTING (Electronic Health Records) .............................................................................. 14

MAINTENANCE OF CERTIFICATION PROGRAM (MOCP) .............................................................. 16

VALIDATION OF SATISFACTORY REPORTING – Measure Applicability Validation ...................... 18

ADDENDUMS ............................................................................................................................................ 20

ADDENDUM A - Eligible Professionals to report the 2013 PQRS Measures ........................................ 20

ADDENDUM B – 2014 Individual & Claims-Based Measure Changes ................................................ 21

ADDENDUM C - GPRO Web Interface Reporting Option ................................................................... 23

ADDENDUM D – EHR Measures ......................................................................................................... 24

ADDENDUM E – 2014 PQRS REPORTING OPTIONS FOR MEASURES GROUPS ....................... 25

ADDENDUM F ...................................................................................................................................... 30

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DEFINITIONS

For the purposes of this manual, the following abbreviations will be used to be in sync with the CMS’

manuals and for simplification purposes:

EP – Eligible professional

QDC (Quality Data Code) – PQRS Code

GP – Group Practice

FFS – Fee for Service

The following are descriptions of terms frequently used when describing quality measures;

Numerator – the PQRS (or QDC) code used to describe the measure(s) reported

Denominator – Qualifying CPT codes used for the measure(s) reported

WHAT IS PQRS? PQRS or the “Physician Quality Reporting System” is a voluntary individual reporting program to report

data on quality measures for covered Physician Fee Schedule (PFS) services furnished to Medicare Part B

beneficiaries (including Railroad Retirement Board and Medicare Secondary Payer). Medicare C

(Medicare Advantage) beneficiaries are not included in claim-based reporting of individual measures or

measure groups, GPRO reporting or EHR Reporting.

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ELIGIBLE PROFESSIONALS (Providers) (EPs) A listing of all providers eligible to participate in 2014 is located in Addendum A at the end of this guide

or you may find the list here on CMS’ website. Included with physicians are PA’s, NPs, psychologists,

social workers, therapists and other non-physician professionals. In 2014, EPs who reassign benefits to a

Critical Access Hospital (CAH) that bills professional services at a facility level can now participate.

PQRS measures are analyzed by the individual NPI number even if the member is part of a group. The

exception is if a group practice of 2 EPs or more reports their measures through the Group Practice

Reporting (GPRO) method, in which case the group’s NPI number would be used in analyzing measure

data.

2014 PQRI BASICS 2014 Incentive Payments will be 0.5% of a provider’s total Medicare allowable charges for

successful reporting

o 2013 was also 0.5%

o 2014 is the last year for reporting PQRS to obtain an incentive payment

PENALTIES - Beginning in 2015, CMS will apply a 1.5% payment adjustment/ penalty under

the PQRS Incentive Program if an EP did not satisfactorily submit data on quality measures for

his/her services for the 2013 quality reporting period. Those EPs who do not successfully submit

PQRS measures in 2014 will incur a 2% penalty applied to their Medicare payments in 2016.

All claims for service dates of January 1, 2014 – December 31, 2014 must be received at CMS by

February 27, 2015, to be included in the analysis for an incentive payment.

There are a total of 284 individual measures and 25 Measures Groups

NEW MEASURES FOR 2014 - 57 new measures to be reported via:

- No new measures were added to Claims-based Reporting

- 18 Individual measures – Registry Reporting Only

- 2 Individual measures - Registry and Measures Groups Reporting

- 16 Measures Groups Measures - Registry Reporting Only

- 18 Individual Measures – EHR Reporting Only

- 3 Measures Groups – Registry Reporting Only

MEASURES RETIRED FOR 2014– 28 measures were retired in 2014 – See Addendum B

EHR REPORTING – Reporting PQRS through a direct or indirect EHR will satisfy the CQM

component of the Medicare EHR Incentive Program. EPs will use the same eCQMs used for the

EHR Incentive Program

REPORTING OPTION CHANGES – Reporting options were added and deleted (See

Addendum B)

- Claims-based Reporting Removed – 17 measures

- EHR Reporting Removed – 6 measures

- EHR Reporting Added – 11 measures

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2014 PQRS REPORTING OPTIONS

Reporting Periods

In 2014, there is only one reporting period of 12 months except for the 6-month reporting period available

for reporting “measures groups” via a registry.

1. 12 months – Service dates of January 1, 2014 – December 31, 2014

2. 6 months – Service dates of July 1, 2014 – December 31, 2014 (for reporting “measures groups”

via a registry only)

Reporting Methods

PQRS quality measures may be reported by individual EPs or Group Practices (GPs) and may be

submitted by the following 5 reporting methods.

A. Individual Measure Reporting

B. Measures Groups Reporting

C. Group Practice Reporting Option (GPRO)

D. Measures Selected by Qualified Clinical Data Registry - new for 2014

E. Certified Survey Vendor – new for 2014

The Administrative Claim Reporting option has been eliminated for 2014 PQRS reporting.

It is important to note that measures were deleted and/or changed in 2014 and 17 measures were removed

from the claim-based reporting method. If a provider participated in the 2013 PQRS program and wants

to report the same measures for the 2014 program, it is essential for the provider to:

Determine if the measures are still available

Check the Release Notes to determine if the criteria for these measures changed in 2014.

Check to see if the measure is available for the reporting method selected by the provider.

The “Release Notes” manuals are specifically written to show only the changes from 2013 to 2014. To

access the Release Notes, see Addendum F.

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Reporting as an Individual EP

To participate in the 2014 PQRS Incentive Program, individual EPs may choose to report information for

individual PQRS quality measures or measures groups.

A. INDIVIDUAL QUALITY MEASURES REPORTING

Individual EPS may report the type of PQRS measures as follows:

1. Individual Measures

2. Measure Groups

3. Qualified Clinical Data Registry

Individual quality measures may be reported to CMS via:

1. Claim-based reporting - on Medicare Part B claims

2. A qualified PQRS Registry

3. A qualified (CEHRT) electronic health record (EHR) product, or

4. A qualified (CEHRT) Data Submission Vendor

Claims-based Reporting – The number of measures to be reported has increased from 2013 from 3

measures to 9 measures.

EPs must report a minimum of 9 measures covering at least 3 NQS domains for at least 50% of

the Medicare Part B FFS patients seen during the reporting period to which the measure applies.

Measures with a 0% performance rate will not be counted.

Providers who report less than 9 measures covering 3 NQS domains will be subject to the

measure-applicability validation (MVA) process. Not reporting measures that EPs could have

reported may disqualify the EP from satisfactory reporting in the PQRS program.

For more information on the measure-applicability validation process and how it is calculated, see

Section 6 “Measure Applicability Validation” of this Guide.

Registry Reporting

EPs must report at least 9 measures covering at least 3 NQS domains for at least 50% of their

Medicare patients eligible for each measure in order to qualify for the incentive payment.

Measures with a 0% performance rate will not be counted.

Providers who report less than 9 measures covering 3 NQS domains will be subject to the

measure-applicability validation (MVA) process. Not reporting measures that EPs could have

reported may disqualify the EP from satisfactory reporting in the PQRS program.

EHR Reporting - Both EHR Direct Product and EHR Data Submission Vendor

EPs must report at least 9 measures covering at least 3 NQS domains .

If an EP’s CEHFT does not contain patient data for at least 9 measures covering at least 3

domains, then the EP must report the measures for which there is Medicare patient data.

An EP must report on at least 1 measure for which there is Medicare patient data.

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B. “MEASURES GROUPS” REPORTING

Measures Groups are a subset of four or more PQRS measures that have a particular clinical condition or

focus in common. Only those measures groups defined by in the PQRS Measures Group document can be

utilized when reporting the measures groups options. All other individual measures that are included in

PQRS but not defined as included in a measures group cannot be grouped together to define a measures

group.

There are 25 measures groups available for reporting in 2014. 3 Measures are new. No measures from

2013 were deleted for 2014 . The new measures groups are:

Total Knee Replacement Measures Group

General Surgery Measures Group

Optimizing Patient Exposure to Ionizing Radiation Measures Groups

With the “measure groups” option, providers may report on a group of clinically-related measures

through a Qualified Registry only. Claims-based reporting is not allowed for measures groups in

2014.

Providers need to report ONE measures group AND report each measures group for at least 20

patients, a majority of which must be Medicare Part B FFS patients to qualify for PQRS payment.

If the EP does not have at least 11 unique Medicare part B FFS patients who meet patient sample

criteria for the measures group, the EP will need to choose another measures group or choose

another reporting option.

Measure groups containing a measure with a 0% performance rate will not be counted

More than one group measure may be reported but the EP will only earn a maximum of one

incentive payment equal to 0.5% of the total estimated allowed charges furnished during the

longest reporting period for which he or she satisfied reporting criteria.

Each measures group has an Intent G Code. This code is used once to inform Medicare that the provider

will be submitting via the Measures Group reporting method and will indicate which measures group will

be reported. It is not necessary to submit the measures group-specific intent G-code for registry-based

submissions. However, the measures group-specific intent G-code has been created for registry only

measures groups for use by registries that utilize claims data.

Each measures group has a Composite Code. This code is used if the EP is reporting on ALL measures

within the measures group. This code is used instead of reporting each measure separately.

The patient sample for the 20 Patient Sample Method is determined by diagnosis and/or specific

encounter parameters common to all measures within a selected measures group. All applicable measures

within a group must be reported for each patient within the sample that meets the criteria (e.g., age or

gender) as published in the Measures Groups Manual.

IMPORTANT: Individual measures within the Measures groups may have different criteria and

specifications than the same measure reported individually. Individual measures within the measures

groups may have also changed since 2013. Therefore, it is important that the requirements for each

measure are reviewed within the specifications and instructions for measures group reporting. These

requirements are provided in a separate manual from the individual measures.

ADDENDUM E - lists all the Measures Groups, the measures within each group, the Intent Code,

Composite Code and how the measures may be submitted.

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ADDENDUM F – lists all of CMS’ Measures Groups’ Manuals and instructions, under the “Measures

Groups” heading.

C. QUALIFIED CLINICAL DATA REGISTRY – New for 2014

The Qualified Clinical Data Registry (QCDR) option is new for 2014 and is distinct and separate from the

qualified registry option also used to submit PQRS data. CMS defines a QCDR as a “CMS approved

entity (such as a registry, certification board, collaborative, etc.) that collect medical and/or clinical data

for the purposes of patient and disease tracking to foster improvement in the quality of care furnished to

patients.”

This program is only available to individual’s that satisfactorily participate or report data on quality

measures for covered Physician Fee Schedule services. Data that may be submitted for the PQRS

program through the QCDR covers quality measures measure across multiple payers and is not limited to

Medicare beneficiaries. The QCDR is also not limited to measures within PQRS. A QCDR may submit

measures from one or more of the following categories with a maximum of 20 non-PQRS measures

allowed:

Clinician and Group Consumer Assessment of Healthcare Providers and Systems (CG CAHPS)

National Quality Forum (NQF)-endorsed measures

Current 2014 PQRS

Measures used by boards or specialty societies, and

Measures used in regional quality collaborations.

Criteria for reporting to earn an incentive :

Report on a minimum of 9 measures covering 3 National Quality Strategy (NQS) domains for at

least 50% of the EPs applicable patients seen during the 2014 participation period.

At least one of the 9 measures must be an outcome measure (containing denominator data

fulfilling both exceptions and exclusions, as well as numerator data)

Alternative Criteria to not earn incentive but avoid the 2016 Payment adjustment:

Report on at least 3 measures covering 1 NQS domain for at least 50 percent of the EP’s

applicable patients seen during the 2014 participation period.

A list of CMS-designated QCDRs will be available on the PQRS website by May 30, 2014.

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Reporting as a Group Practice

A. GROUP PRACTICE REPORTING (GPRO)

A GPRO practice is defined as a single TIN with 2 or more EPs, as identified by their NPI, who have

reassigned billing rights to the TIN.

There will be 22 measures available for GPRO reporting which includes subcomponent of composite

measures. There were no new or deleted measures for 2014. However, descriptions and requirements of

the measures may have changed.

Requirements to be considered as a 2014 PQRS GPRO

Have billed Medicare Part B PFS on or after January 1, 2014 and prior to December 31, 2014;

Agree to have the results on the performance of their PQRS measures publicly posted on the

Physician Compare website;

Have the following technical capabilities, at a minimum: standard PC image with

Microsoft®Office and Microsoft® Access software installed; and minimum software

configurations (only applies to group practices reporting via the Web Interface);

Be able to comply with a secure method for data submission;

Allow CMS access to review the Medicare beneficiary data on which PQRS GPRO submissions

are founded or provide to CMS a copy of the actual data;

Indicate desire to participate in PQRS through the GPRO via registration; and

Provide all requested data through the Physician Value-Physician Quality Reporting System (PV-

PQRS) Registration System during registration.

Methods for submitting:

GPRO web interface provided by CMS (25+ EPs)

Qualified PQRS Registry (2+ EPs)

EHR Direct Product that is CEHRT (2+ EPs) – new for GPRO in 2014

EHR data submission vendor that is CERT (2+ EPs) – new for GPRO in 2014

CMS-certified survey vendor (25+ EPs) – new method of 2014

The method chosen is the only PQRS submission method available to the group and all individual NPIs

that bill Medicare under the group’s TIN. This means that some EPs in the group cannot bill individually

and others bill under GPRO. Submission requirements depend on the size of the group practice.

Groups 2+ EPs o QUALIFIED REGISTRY – must report on at least 9 measures covering at least 3 of the

NQS domains and report each measure for at least 50 percent of the group practice’s

Medicare Part B FFS patients seen during the reporting period to which the measure

applies. Measures with a 0 percent performance rate would not be counted. For a group

practice that reports less than 9 measures covering at least 3 domains, the group practice

will be subject to the MAV process.

o DIRECT CEHRT EHR or EHR CEHRT DATA SUBMISSION VENDOR – must report

on at least 9 measures covering at least 3 of the NQS domains and if an EP’s CEHFT

does not contain patient data for at least 9 measures covering at least 3 domains, then the

EP must report the measures for which there is Medicare patient data. A group practice

must report on at least one measure for which there is Medicare patient data.

Groups 25+ EPs o CMS CERTIFIED SURVEY VENDOR – Report all CG CAHPS survey measures via a

CMS-Certified survey vendor AND report at least 6 measures covering at least 2 of the

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NQS domains using a QUALIFIED REGISTRY, DIRECT EHR PRODUCT, EHR

DATA SUBMISSION VENDOR OR GPRO WEB INTERFACE.

Groups 25-99 EPs o GPRO WEB INTERFACE - Must report on all 17 GPRO measures including two

composite measures for a total of 22 measures in 7 disease modules included in the

GPRO Web Interface; AND must populate the remaining data fields for the first 218

consecutively ranked and assigned beneficiaries in the order in which they appear in the

group’s sample for each module or preventive care measure. If the pool of eligible

assigned beneficiaries is less than 218, then report on 100 percent of assigned

beneficiaries

Groups 100+ EPs o GPRO WEB INTERFACE - Must report on all 17 GPRO measures included in the GPRO

Web Interface as above; AND Populate data field for the first 411 consecutively ranked

and assigned beneficiaries in the order in which they appear in the group’s sample for

each disease module or preventive care measure. If the pool of eligible assigned

beneficiaries is less than 411, then report on 100 percent of assigned beneficiaries. In

addition, the GP must also report all CG CAHPS survey measures via certified survey

vendor

GPRO Eligibility Criteria

Individual EPs who are members of a GP selected to participate in the PQRS GPRO program are not

eligible to separately earn a PQRS incentive payment as an individual EP under that same TIN. Once a

GP’s TIN is selected to participate in the GPRO; this is the only method of PQRS reporting available to

the group and all individual NPIs who bill Medicare under the group’s TIN number.

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GPRO Web Interface Reporting (25 or more EPs)

There will be 22 measures available for GPRO reporting which includes subcomponent of composite

measures. There were no new or deleted measures for 2014. However, descriptions and requirements of

the measures may have changed.

The GPRO Web Interface is a web-based reporting tool that is partially pre-populated with an assigned

sample of Medicare Part B PFS beneficiaries; this sample is based on the claims history for the group

practice, and contains demographic and utilization information for those assigned beneficiaries. GPs will

be required to populate all of the remaining data fields necessary for capturing quality measure

information for each consecutively assigned Medicare beneficiary (218 beneficiaries for groups with 25-

99 EPs or 411 beneficiaries for groups with 100+ EPs) with respect to services furnished during the 2014

reporting period. GPs will be able to access the Web interface for 2014 data submission during the first

quarter of 2014.

Group practices participating in the 2014 PQRS GPRO via the Web Interface are required to report on all

17 quality measures (including two composite measures for a total of 22 measures) in seven disease

modules including:

Care Coordination/Patient Safety (Care),

Preventive Care (PREV),

Coronary Artery Disease (CAD),

Diabetes Mellitus (DM),

Heart Failure (HF),

Hypertension (HTN), and

Ischemic Vascular Disease (IVD).

See Addendum C for GPRO Measures.

Measure specifications and supporting documents will be available in the fall of 2014 on the PQRS

GPRO Web Interface website: http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-

Instruments/PQRS/GPRO_Web_Interface.html.

Complete information about reporting 2014 PQRS through the GPRO via Web Interface is available on

the Web Interface section of the CMS website at http://www.cms.gov/Medicare/Quality-Initiatives-

Patient-Assessment-Instruments/PQRS/GPRO_Web_Interface.html.

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Registration to Participate as a GPRO

Registration must be completed through the Physician Value-Physician Quality Reporting (PV-PQRS)

Registration System by September 30, 2014. This is a web-based application that serves the PV-PQRS

programs. At the time of registration, GPs must indicate their reporting method though they may change

this method at any time prior to the September 30, 2014 deadline. Groups who register for the 2014

PQRS GPRO will not be able to withdraw their registration.

Here are the registration basics:

Go to https://portal.cms.gov. On the right hand side, select Login to CMS Secure Portal.

After accepting the Terms and Conditions, enter your IACS User ID and Password in the

Welcome to CMS Enterprise Portal screen. Select Login to continue.

Select the PV-PQRS tab at the top of the screen, and then select Registration from the dropdown

menu.

You will see a screen where the group practice(s) and EP(s) (if applicable) that are associated

with your IACS account are listed. To register a group practice for the first time, select the

Register link to the right of the group practice you want to register.

Note: If your group practice is participating in an Accountable Care Organization (ACO) , then you will

see an alert message letting you know that it is not necessary for you to register the group practice or EP

(if applicable) in the PV-PQRS Registration System.

Complete registration information and step-by-step instructions for IACS and 2014PQRS GRPO

Registration will be available on the Self-Nomination/Registration page of the Physician Feedback

Program website. At the time of publishing this resource guide, complete instructions for 2014 were not

yet on the CMS website.

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B. Certified Survey Vendor - New for 2014

The CMS-certified survey vendor is a new reporting mechanism available to group practices of 25+EPs

taking part in PQRS under the GPRO beginning in 2014. This method reports the Clinician & Group

Consumer Assessment of Healthcare Providers and Systems (CG CAHPS) survey and is a survey taken

by patients based on their experience and care from the reporting group practice.

Group practices can earn a 2014 PQRS Incentive and avoid the 2016 PQRS payment adjustment by

meeting the following criteria.

Groups of 25-99 EPs (This survey is optional for this GP. CMS will not bear the cost of administering

this survey. The GP must:

report all 12 CG CAHPS summary survey modules via a CMS-certified survey vendor, AND

report at least 6 measures covering at least 2 of the NQS domains using a qualified registry, a

CEHRT direct product, or a CEHRT data submission vendor, OR

Report all 22 GPRO Web Interface composite measures

Groups of 100+ EPs (This is a requirement for these GPs and CMS will bear the cost of administering

this survey) The GPs must report:

All 12 CG CAHPS summary survey modules via a CMS-certified survey vendor AND

Complete all 22 GPRO Web Interface composite measures

The 12 CG CAHPS summary survey modules will include the following:

o Getting timely care, appointments, and information

o How well providers communicate

o Patient’s rating of provider

o Access to specialists

o Health promotion & education

o Shared decision making

o Health status/functional status

o Courteous and helpful office staff

o Care coordination

o Between visit communication

o Helping you to take medication as directed

As of this publishing date, CMS has not issued the list of CME-certified survey vendors. It is expected

that CMS will issue this listing soon.

For more information on the CMS-Certified Survey Vendor, see Addendum F under the title CMS-

Certified Vendors.

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2014 REPORTING MECHANISMS

There are 5 mechanisms to report PQRS Data:

A. Claims-based Reporting

B. Registry Reporting

C. EHR Direct and EHR Vendor Submission Reporting

D. CMS-Certified Survey Vendor – New for 2014

A. CLAIMS-BASED REPORTING

PQRS measures are reported on each claim submitted to Medicare when the CPT and diagnosis

combination qualifies for the PQRS measures the provider has chosen. Instructions for billing via this

method are contained in Addendum G at the end of this Guide. Submission of PQRS may be by:

Individual Measures only

B. REGISTRY REPORTING

Professionals may submit their measures through a Registry. A registry is a third-party database that

many professionals already use to report data to researchers about common care processes for diabetes,

kidney disease and preventive medicine. An EP or group practice would be required to enter into and

maintain an appropriate legal arrangement with a qualified PQRS registry. The Registry would act as a

HIPAA Business Associate and agent of the EP.

Each eligible professional or group participating in GPRO must satisfactorily report on at least 50 percent

of eligible instances for at least nine measures across three NQS domains to qualify for the 2014 PQRS

incentive payment. If fewer than nine measures or if less than three NQS domains are reported via a

qualified registry, CMS will apply a measure-applicability validation (MAV) process when determining

incentive eligibility.

Eligible professionals or group practices participating in GPRO should work directly with the

participating registry for more information on how to submit data on the selected measures or measures

group. The 2014 PQRS data submission window will be in the first quarter of 2015.

Once an EP or group practice knows what measures will be reported, they should review the list of

registries that report 2014 PQRS measures and select one that reports the same measures. Not all

registries report all measures and so it is important to ensure the registry selected is one that reports the

selected measures.

CMS has published the 2014 qualified registries on their PQRS website. You may visit the 2014

Qualified Registry Vendors site to get an idea of the services they offer, their contact information and

cost.

More information on the qualified registry option can be found in ADDENDUM F, under Qualified

Registry Reporting

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C. EHR REPORTING (Electronic Health Records)

The criteria for satisfactory reporting, as well as the Clinical Quality Measures (CQMs) available for

reporting under the PQRS EHR-based reporting mechanism, are aligned with the Medicare EHR

Incentive Program and the e-CQM specifications will be used for both programs.

For 2014 and beyond, CMS will discontinue the PQRS qualification requirement for Data Submission

vendors and Direct EHR vendors. The EHR products will have to be certified (CEHRT) under the

program established by ONC. (Office of Nat’l Coordination for Health Information Technology) For

purposes of PQRS, the EPs or group practices (GPs) direct EHR product or EHR Data Submission

Vendor must be certified to the CMS specified versions of the e-CQMs.

PQRS requires the use of specific versions of the e-CQMS, which may differ from the EHR Incentive

Program e-CQM version. EPs and group practices reporting PQRS through the EHR -based reporting

method are required to use the June 2013 version of the e-CQMs. (The exception to this is CMS140,

which is to be reported using the December 2012 version (CMS140v1). DEPs and GPs wishing to report

another version of this measure must do so by attestation, which will only count for the EHR Incentive

Program and not for PQRS. )

There are 64 CQM measures available for EHR reporting in 2014.

See Addendum A for the CQM measures with the June 2013 CQM version numbers used for the

PQRS program.

The EHR Incentive program December 2012 CQM version numbers are listed here .

If an EP or GP satisfactorily reports for 2014 PQRS using the EHR-based reporting option, the EP or GP

will also satisfy the CQM component of the EHR Incentive Program; however, EPs (including individual

EPs inside the GP)will still be required to meet the other Meaningful Use objectives through the Medicare

EHR Incentive Program Registration and Attestation System.

Individual : EPs must report on at least 9 measures covering 3 National Quality Strategy (NQD)

domains.

If the EP’s CEHRT(Certified EHR technology) does not contain patient data for at least 9

measures covering at least 3 domains, then the EP must report the measures for which there is

Medicare patient data.

An EP must report on at least 1 patient for which there is Medicare patient data.

Group Practices – A group practice(GP) must register with CMS to report via EHR under the GPRO for

2014 PQRS.

GPs must report on at least 9 measures covering 3 National Quality Strategy (NQD) domains.

If the GP’s CEHRT does not contain patient data for at least 9 measures covering at least 3

domains, then the GP must report the measures for which there is Medicare patient data.

A GP must report on at least 1 patient for which there is Medicare patient data.

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Direct and Indirect EHR Reporting

Data submitted through a Direct EHR vendor EHR product OR DSV must be transmitted using the

QDM-based QRDA Category I or III formats. Although products must be able to transmit data using the

QDM-based QRDA Category I and III formats, for purposes of reporting PQRS quality measures data to

CMS, EPs and GPs need only submit data via their EHR using one of these formats.

For 2014, EPs may submit quality measure data to CMS:

1. Directly from the EP’s (eligible professional) CEHRT (Certified EHR Technology) qualified

EHR in the CMS-specified manner , or

2. Indirectly from a CEHRT qualified EHR data submission vendor (on the EP’s behalf), in the

CMS-specified manner.

Direct EHR Vendor If submitting directly, EPs and GPs must register for an IACS account. Information on registering for an

IACS account can be found on the “Physician and Other Health Care Professionals Quality Reporting

Portal” (Portal) at https://www.qualitynet.org/portal/server.pt/community/pqri_home/212

Request the appropriate Submitter Role when registering for an IACS account – either Individual

PQRS Submitter and PQRS Representative, or PQRS Submitter.

If you already have an IACS account, you will need to request adding the role to your account.

Refer to the IACS Quick Reference Guides document on the Portal home page

If assistance is needed, contact eh QualityNet Help Desk at 866-715-6922 or via email at

[email protected]

Indirect EHR Data Submission Vendor (DSV) – A DSV is an entity vendor that collects an EP’s or

group practices’ clinical data directly from the EP’s or GP’s EHR. DSVs will be responsible for

submitting PQRS measures data from an EP’s or GP’s certified EHR to CMS in a CMS-specified

format(s) on behalf of the EP or GP.

Submission of Clinical Quality Measures (eCQMs) EPs and group practices must submit final EHR reporting files with quality measure data, or ensure that

their EHR Data Submission Vendor submits files by the data submission deadline of February 28, 2015,

to be analyzed and used for 2014 PQRS EHR measure calculations.

If reporting QDM-based QRDA Category I files, a single file must be uploaded/submitted for

each patient. Files can be batched but there will be file upload size limits. It is likely that several

batched files will need to be uploaded to the Portal for each eligible provider.

Following each successful file upload, notification will be sent to the IACS user’s e-mail address

indicating the files were submitted and received.

Submission reports will then be available to indicate file errors, if applicable.

Reporting via EHR using the QRDA Category III format is one of three reporting methods

(Registry, EHR, and QCDR) that provide calculated reporting and performance rates to CMS.

Note: Measures with a 0% performance rate will not be counted.

CMS web pages dedicated to EHR reporting may be found in ADDENDUM F, under EHR Reporting.

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MAINTENANCE OF CERTIFICATION PROGRAM (MOCP)

EPs can earn another 0.5% of their allowed Medicare charges in addition to the .5% earned through the

PQRS incentive program by participating in the Maintenance of Certification Program (MOCP). The

MOCP is a continuous assessment program that advances quality and the life- long learning and self-

assessment of board certified specialty physicians by focusing on the competencies of patient care,

medical knowledge, practice-based learning, interpersonal and communication skills and professionalism.

A physician must successfully participate in the 2014 PQRS program to be eligible for the 2014 MOCP

incentive. As with the PQRS incentive payment, the MOCP incentive payment will be based on allowed

Medicare Part B Physician Fee Schedule charges for professional services furnished between January 1,

2014 and December 31, 2014.

The 0.5 % MOC incentive will be issued in addition to the PQRS 0.5% incentive earned in 2014 and will

be paid at the same time as the PQRS incentive payment. Physicians cannot receive more than one

additional 0.5% incentive, even if they complete a Maintenance of Certification Program in more than

one specialty.

Physicians who do not have an available MOCP practice assessment through their boards or otherwise,

are not eligible for the 0.5% incentive. (See below for the 2013 Qualified MOC Entities)

Some of the specialties able to participate in 2013 were:

- Allergy & Immunology - Obstetrics & Gynecology

- Anesthesiology - Pathology

- Emergency Medicine - Psychiatry and Neurology

- Internal Medicine - Radiology

- Family Medicine - Surgery

- Nuclear Medicine

The general requirements for participation in the 2014 MOCP Incentive are as follows:

Physicians must be board-certified

Physicians must meet the requirements for satisfactory reporting or satisfactory participation via a

qualified clinical data registry (QCDR) under PQRS and participate via:

o the 12-month 2014 PQRS reporting period as an individual EP using either individual

PQRS measures or measure groups, and submitting the PQRS data via claims, registry,

direct EHR-based product or EHR data submission vendor that is a Certified EHR

Technology (CEHRT), qualified clinical data registry , or

o under the PQRS group practice reporting option (GPRO) for a 12-month reporting period

o Identify a MOCP that has become qualified for purposes of the 2014 PQRS MOCP

Incentive Program. See the Qualified Maintenance of Certification Entities for

2013. The final list of 2014 certification entities will be published on the CMS website by

mid-2014.

AND The Maintenance of Certification Program entity will need to submit to CMS, on behalf of the physician

the following information:

That the physician more frequently than is required to qualify for or maintain board certification

status, participates in the MOCP for a year and successfully completes a MOC practice

assessment for such year;

Information on the survey of patient experience with care; and

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The methods, measures, and data used under the MOC and the qualified MOC practice

assessment.

The MOCP entities will manage the program as well as submit the 2014 information on behalf of

physicians by February 27, 2015.

Complete instructions and information concerning the CMS MOCP can be found on their website at the

following links:

Maintenance of Certification Program Incentive Made Simple

Maintenance of Certification Program Requirements

MOCP SELF-NOMINATION

New and previously approved MOCP entities who wish to enable their members to be eligible for the

additional incentive need to complete the self-nomination process by January 31, 2014, and will need to

be approved for participation by CMS.

Boards that were previously qualified as an MOCP entity or newly participating boards that utilize a

previously qualified registry for their MOCP data, will not need to undergo the qualification process.

However, these entities must still go through the self-nomination process each year they want to

participate in the program.

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VALIDATION OF SATISFACTORY REPORTING – Measure Applicability

Validation

When an EP reports on fewer measures than the reporting method calls for, CMS will perform a review

(measure applicability validation (MVA))to determine whether there are other closely related measures

(such as those that share a common diagnosis or those that are representative of services typically

provided by a particular type of EP. In this case, if the EP does not report on those additional measures,

then the EP will not earn an incentive payment on the measures reported.

The MVA will be applied to those EPs who submit PQRS measures through a claim-based or registry

reporting method.

Prerequisites for MAV

Eligible professionals who satisfactorily report QDCs for only one to eight PQRS measures

across one or more domains, OR eligible professionals who satisfactorily report QDCs for nine

or more PQRS measures across less than three domains

Eligible professionals must satisfactorily report for at least 50 percent of their eligible patients or

encounters for each measure o

o To receive 2014 incentive payment, CMS will analyze claims data to validate if more

measures/domains may have been applicable for reporting

o To avoid 2016 payment adjustment, if only one or two measures are satisfactorily

reported , CMS will analyze claims data to validate if more measures may have been

applicable for reporting

o EPs that satisfactorily report three or more measures across one or more domains will not

be subject to MAV for payment adjustment purposes, but will be subject to MAV to

determine if more measures/domains could have been submitted for 2014 incentive

eligibility.

• A performance rate greater than 0% [or less than 100% where a lower performance rate indicates

better performance (inverse measures)]

• EPS who do not submit any QDCs for any other measure will be subject to the MAV process

Those who fail the validation process will not earn the PQRS incentive payments.

CMS will apply a two-step process to operationalize the MVA.

1. Clinical Relation Test/Domain

2. Minimum Threshold Test

Step 1: Clinical Relation Test

This test is based on:

1. A presumption that if a provider submits data for a measure, then that measure applies to her/his

practice and

2. The concept that if one measure in a cluster of measures related to a particular clinical topic or

professional service is applicable to a provider’s practice, then other closely-related measures

(measures in that same cluster) may also be applicable.

The following is an example of how the clinical relation test will be applied:

A provider submitted PQRS codes for one of the PQRS measures related to pneumonia. (pneumonia has 4

separate measures) That EP’s claims will then be analyzed using the minimum threshold test described

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below to determine whether another pneumonia measure (or two more pneumonia measures) could also

have been submitted.

Step 2: Minimum Threshold Test.

The minimum threshold test is based on the concept that only if, during the 2014 reporting period, a

provider treated more than a certain number of Medicare patients with a condition to which a certain

measure applied, then that EP should be accountable for submitting the QDC(s) for that measure.

For the 2014 reporting period, the common minimum threshold, based on statistical and clinical

frequency considerations, will not be less than 15 patients or encounters for the 12-month reporting period

for each 2014 measure.

CMS examples of how the minimum threshold test will be applied:

An endocrinologist treated 20 Medicare patients with diabetes during the 2014 12-month reporting period.

If that endocrinologist is subject to validation and was found to have submitted a PQRS/QDC code for at

least one of the diabetes measures under the clinical relation test, then the physician would be deemed

responsible for submitting PQRS/QDC codes for the other PQRS diabetes cluster measures. If the

additional codes were not submitted, the provider will not earn the 2014 incentive payment.

Alternatively, if an internist was subject to validation and was found to have submitted a

PQRS code for at least one of the pneumonia measures under the clinical relation test but treated only 2

Medicare patients with pneumonia during the same period, then the internist would not be responsible for

submitting the additional pneumonia measures and would not be precluded from receiving an incentive

payment.

During the reporting period, CMS will determine a minimum threshold for each individual PQRS

measure based on analysis of Part B claims data. However, no threshold will fall below the common

threshold of 15 patients or encounters described above.

CMS may determine that it is necessary to modify the measure-applicability validation process after the

start of the reporting periods. However, any changes will result in the process being applied more

leniently, thereby (1) allowing a greater number of professionals to pass validation and (2) causing no

professional who would otherwise have passed to fail.

Information concerning the Validation Process along with a listing of the validation clusters can be found

in ADDENDUM F, under the heading, Applicability Validation.

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ADDENDUMS

ADDENDUM A - Eligible Professionals to report the 2013 PQRS Measures

1. Medicare physicians

Doctor of Medicine

Doctor of Osteopathy

Doctor of Podiatric Medicine

Doctor of Optometry

Doctor of Oral Surgery

Doctor of Dental Medicine

Doctor of Chiropractic

2. Practitioners

Physician Assistant

Nurse Practitioner *

Clinical Nurse Specialist *

Certified Registered Nurse Anesthetist (and Anesthesiologist Assistant)

Certified Nurse Midwife*

Clinical Social Worker

Clinical Psychologist

Registered Dietician

Nutrition Professional

Audiologists

*Includes Advanced Practice Registered Nurse (APRN)

3. Therapists

Physical Therapist

Occupational Therapist

Qualified Speech-Language Therapist (as of 7/1/2009)

Please Note: Beginning in 2014, professionals who reassign benefits to a Critical Access Hospital (CAH) that bills

professional services at a facility level, such as CAH Method II billing, can now participate (in all reporting methods

except for claims-based) in PQRS. To do so, the CAH must include the individual provider NPI on their institutional

(FI) claims.

Eligible But Not Able to Participate Some professional may be eligible to participate per their specialty, but due to billing method may not be able to

participate.

Professionals, who do not bill Medicare at an individual National Provider Identifier (NPI) level, where the

rendering provider’s individual NPI is entered on CMS-1500 type paper or electronic claims billing,

associated with specific line-item services.

Services payable under fee schedules or methodologies other than the PFS are not included in PQRS such as

services provided in federal qualified health center, independent diagnostic testing facilities, independent

laboratories, hospitals (including method I critical access hospitals), rural health clinics, ambulance providers, and

ambulatory surgery center facilities.

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ADDENDUM B – 2014 Individual & Claims-Based Measure Changes

2014 New Individual Measures #329: Adult Kidney Disease: Catheter Use at Initiation of Hemodialysis - Registry

#330: Adult Kidney Disease: Catheter Use for Greater Than or Equal to 90 Days - Registry

#331: Adult Sinusitis: Antibiotic Prescribed for Acute Sinusitis (Appropriate Use) - Registry

#332: Adult Sinusitis: Appropriate Choice of Antibiotic: Amoxicillin Prescribed for Patients with Acute Bacterial

Sinusitis - Registry

#333: Adult Sinusitis: Computerized Tomography (CT) for Acute Sinusitis (Overuse) – Registry

#334: Adult Sinusitis: More than One Computerized Tomography (CT) Scan Within 90 Days for Chronic Sinusitis

(Overuse) - Registry #335: Maternity Care: Elective Delivery or Early Induction Without Medical Indication at ≥ 37 and < 39 Weeks -

Registry

#336: Maternity Care: Post-Partum Follow-Up and Care Coordination - Registry

#337: Tuberculosis Prevention for Psoriasis and Psoriatic Arthritis Patients on a Biological Immune Response

Modifier - Registry

#338: HIV Viral Load Suppression – Registry, Measures Groups

#339: Prescription of HIV Antiretroviral Therapy - Registry, Measures Groups

#342: Pain Brought Under Control Within 48 Hours - Registry

#343: Screening Colonoscopy Adenoma Detection Rate

#344: Rate of Carotid Artery Stenting (CAS) for Asymptomatic Patients, Without Major Complications (Discharged

to Home by Post-Operative Day #2) - Registry

#345: Rate of Postoperative Stroke or Death in Asymptomatic Patients Undergoing Carotid Artery Stenting (CAS) -

Registry

#346: Rate of Postoperative Stroke or Death in Asymptomatic Patients Undergoing Carotid Endarterectomy (CEA) -

Registry

#347: Rate of Endovascular Aneurysm Repair (EVAR) of Small or Moderate Non-Ruptured Abdominal Aortic

Aneurysms (AAA) Who Die While in Hospital - Registry

#348: HRS-3 Implantable Cardioverter-Defibrillator (ICD) Complications Rate

#349: Optimal Vascular Care Composite - Registry

#358: Patient-centered Surgical Risk Assessment and Communication - Registry

2014 Retired PQRS Measures

#3: Diabetes Mellitus: High Blood Pressure Control

#86: Hepatitis C: Antiviral Treatment Prescribed

#89: Hepatitis C: Counseling Regarding Risk of Alcohol Consumption

#90: Hepatitis C: Counseling Regarding Use of Contraception Prior to Antiviral Therapy

#161: HIV/AIDS: Adolescent and Adult Patients with HIV/AIDS Who Are Prescribed Potent Antiretroviral

Therapy

#162: HIV/AIDS: HIV RNA Control After Six Months of Potent Antiretroviral Therapy

#184: Hepatitis C: Hepatitis B Vaccination in Patients with HCV

#188: Referral for Otologic Evaluation for Patients with Congenital or Traumatic Deformity of the Ear

#200: Heart Failure: Warfarin Therapy for Patients with Atrial Fibrillation

#201: Ischemic Vascular Disease (IVD): Blood Pressure Management

#208: HIV/AIDS: Sexually Transmitted Disease Screening for Syphilis

#209: Functional Communication Measure - Spoken Language Comprehension

#210: Functional Communication Measure – Attention

#211: Functional Communication Measure – Memory

#212: Functional Communication Measure - Motor Speech

#213: Functional Communication Measure – Reading

#214: Functional Communication Measure - Spoken Language Expression

#215: Functional Communication Measure – Writing

#216: Functional Communication Measure – Swallowing

#237: Hypertension (HTN): Blood Pressure Measurement

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#244: Hypertension: Blood Pressure Management

#252: Anticoagulation for Acute Pulmonary Embolus Patients

#256: Surveillance after Endovascular Abdominal Aortic Aneurysm Repair (EVAR)

#306: Prenatal Care: Screening for Human Immunodeficiency Virus (HIV)

#307: Prenatal Care: Anti-D Immune Globulin

#308: Smoking and Tobacco Use Cessation, Medical Assistance: a. Advising Smokers and Tobacco Users to Quit,

b. Discussing Smoking and Tobacco Use Cessation Medications, c. Discussing Smoking and Tobacco Use

Cessation Strategies

#313: Diabetes Mellitus: Hemoglobin A1c Control (< 8%)

#321: Participation by a Hospital, Physician or Other Clinician in a Systematic Clinical Database Registry that

Includes Consensus Endorsed Quality

Measures Removed From Claims-Based Reporting

#9 Anti-depressant Medication Management

#53 Asthma: Pharmacologic Therapy for Persistent Asthma - Ambulatory Care Setting

#64 Asthma: Assessment of Asthma Control – Ambulatory Care Setting Claims

#65 Appropriate Treatment for Children with Upper Respiratory Infection (URI)

#66 Appropriate Testing for Children with Pharyngitis

#84 Hepatitis C: Ribonucleic Acid (RNA) Testing Before Initiating Treatment

#85 Hepatitis C: HCV Genotype Testing Prior to Treatment

#87 Hepatitis C: Hepatitis C Virus (HCV) Ribonucleic Acid (RNA) Testing Between 4-12 Weeks After Initiation of

Treatment

#116 Avoidance of Antibiotic Treatment in Adults with Acute Bronchitis

#126 Diabetes Mellitus: Diabetic Foot and Ankle Care, Peripheral Neuropathy – Neurological

#127 Diabetes Mellitus: Diabetic Foot and Ankle Care, Ulcer Prevention – Evaluation of Footwear

#176 Rheumatoid Arthritis (RA): Tuberculosis Screening

#177 Rheumatoid Arthritis (RA): Periodic Assessment of Disease Activity

#178 Rheumatoid Arthritis (RA): Functional Status Assessment

#179 Rheumatoid Arthritis (RA): Assessment and Classification of Disease Prognosis

#180 Rheumatoid Arthritis (RA): Glucocorticoid Management

#183 Hepatitis C: Hepatitis A Vaccination in Patients with Hepatitis C Virus (HCV)

NQS Domains Patient and Family Engagement

Patient Safety

Care Coordination

Population/Public Health

Efficient Use of Healthcare Resources

Clinical Process/Effectiveness

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ADDENDUM C - GPRO Web Interface Reporting Option

GPRO Web Interface Reporting Option Measures

Alternative Measure Numbers & Reporting Options

GPRO # Measure Title PQRS ACO NQF CMS

Care Coordination/Patient Safety and Preventive Care Measures

CARE-1 Medication Reconciliation CR 46 12 0097 N/A

CARE-2 Falls: Screening for Future Fall Risk GO 318 13 0101 139v2

Coronary Artery Disease (CAD) Disease Module (2 Components of 1 CompositeMeasure) CAD Composit: (All or Nothing Scoring)

CAD-2 CAD Composite (All or nothing scoring); Coronary Artery Disease(CAD):Lipid Control R 197 32 0074 N/A

CAD-7 CAD Composite (All or nothing scoring); Coronary Artery Disease(CAD):Angiotensin-Converting Enzyme(ACE) Inhibitor or Angiotensin..) R 118 32 0066 N/A

Disease Mellitus (DM) Disease Module ( 1 Individual Measure & 1 Composite Measure)

DM-2 Diabetes: Hemoglobin A 1c Poor Control CR1 27 0059 122v2

Diabetes Composite: Optimal Diabetes Care (5 Components of 1 Compostie Measure) Diabetes Composite: (All of Nothing Scoring)

DM-13 Diabetes Composite (All or Nothing Scoring): Diabetes Mellitus: High Blood Pressure Control GO 319 24 0729 NA

DM-14 Diabetes Composite (All or Nothing Scoring): Diabetes Mellitus: Low Density Lipoprotein (LDL-C) Control GO 319 23 0729 NA

DM-15 Diabetes Composite (All or Nothing Scoring): Diabetes Mellitus: Hemoglobin A 1c Control(<8%) GO 319 22 0729 NA

DM-16

Diabetes Composite (All or Nothing Scoring): Diabetes Mellitus: Daily Aspirin or Antiplatelet Medication Use for Patients w/Diabetes and Ischemic Vascular Disease GO 319 26 0729 NA

DM-17 Diabetes Composite (All or Nothing Scoring): Diabetes Mellitus: Tobacco Non-Use GO 319 25 0729 NA

Heart Failure (HF) Disease Module (1 Measure)

HF-6 Heart Failure: Beta-Blocker Therapy for Left Ventricular Systolic Dysfunction(LVSD) R 8 31 0083 144v2

Hypertension (HTN) Disease Module (1 Measure)

HTN-2 Controlling High Blood Pressure CR 236 28 0018 165v2

Ischemic Vascular Disease (IVD) Disease Module (2 Measures)

IVD-1 Ischemic Vascular Disease (IVD): Complete Lipid Panel and LDL Control CR 241 29 0075 182v2/3

IVD-2 Ischemic Vascular Disease (IVD): Use of Aspirin or Another Antithrombotic CR 204 30 0068 164v2

Preventive (PREV) Care Measures (8 Measures - Individually Sampled)

PREV-5 Breast Cancer Screening CR 112 20 NQF NA 125v2

PREV-6 Colorectal Cancer Screening CR 113 19 0034 130v2

PREV-7 Preventive Care and Screening: Influenza Immunization CR 110 14 0041 147v2

PREV-8 Pneumonia Vaccination Status for Older Adults CR 111 15 0043 127v2

PREV-9 Preventive Care and Screening: Body Mass Index (BMI) Screening & Follow-up CR 128 16 0421 69v2

PREV-10

Preventive Care and Screening: Tobacco Use; Screening and Cessation Intervention CR 226 17 0028 138v2

PREV-11

Preventive Care and Screening: Screening for High Blood Pressure and Follow-up Documented CR 317 21 NA 22v2

PREV-12

Preventive Care and Screening: Screening for Clinical Depression and Follow-up Plan CR 134 18 0418 2v3

CR = Claims/Registry, GO= GPRO Only, R= Registry Only

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ADDENDUM D – EHR Measures

2014 New EHR MEASURES

As of this writing, measure numbers are not available. - Hemoglobin A1c Test for Pediatric Patients

- ADHD: Follow-up Care for Children Prescribed Attention-Deficit/Hyperactivity Disorder (ADHD) Medication

- Bipolar Disorder and Major Depression: Appraisal for alcohol or chemical substance use - HIV/AIDS: Medical

Visit

- Pregnant women that had HBsAg testing

- Depression Remission at Twelve Months

- Depression Utilization of the PHQ-9 Tool

- Maternal Depression Screening

- Hypertension: Improvement in Blood Pressure

- Closing the referral loop: receipt of specialist report

- Functional Status Assessment for Knee Replacement

- Functional Status Assessment for Hip Replacement

- Functional Staus Assessment for Complex Chronic Conditions

- Children who Have Dental Decay or Cavities

- Primary Carier Prevention Intervention as Offered by Primary Care Providers, including Dentists

- ADE Prevention and Monitoring: Warfarin Time in Therapeutic Range

- HIV/AIDS: RNA Control for Patients with HIV

- Child and Adolescent Major Depressive Disorder (MDD): Suicide Risk Assessment

Measures Removed from EHR Reporting

#6 Coronary Artery Disease (CAD): Antiplatelet Therapy

#39 Screening or Therapy for Osteoporosis for Women Aged 65 Years and Older

#47 Advance Care Plan

#48 Urinary Incontinence: Assessment of Presence or Absence of Urinary Incontinence in Women Aged 65 Years

and Older

#64 Asthma: Assessment of Asthma Control – Ambulatory Care Setting Claims Removed

#197 Coronary Artery Disease (CAD): Lipid Control

Measures Added to EHR Reporting #9 Anti-depressant Medication Management

#65 Appropriate Treatment for Children with Upper Respiratory Infection (URI)

#107 Adult Major Depressive Disorder (MDD): Suicide Risk Assessment

#130 Documentation of Current Medications in the Medical Record

#134 Preventive Care and Screening: Screening for Clinical Depression and Follow-Up Plan

#143 Oncology: Medical and Radiation – Pain Intensity Quantified

#160 HIV/AIDS: Pneumocystis Jiroveci Pneumonia (PCP) Prophylaxis

#191 Cataracts: 20/40 or Better Visual Acuity within 90 Days Following Cataract Surgery

#192 Cataracts: Complications within 30 Days Following Cataract Surgery Requiring Additional Surgical

Procedures

#281 Dementia: Cognitive Assessment

#318 Falls: Screening for Future Fall Risk

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ADDENDUM E – 2014 PQRS REPORTING OPTIONS FOR MEASURES

GROUPS

(Strike-though measures – 2013 measures eliminated as part of the measures grouping in 2014)

Measures Groups may only be reported through the Quality Registry Option.

DIABETES MELLITUS MEASURES GROUP:

Intent Code: G8485 Composite Code: G8494 # 1. Diabetes Mellitus: Hemoglobin A1c Poor Control in Diabetes Mellitus

# 2. Diabetes Mellitus: Low Density Lipoprotein (LDL-C) Control in Diabetes Mellitus

# 3. Diabetes Mellitus: High Blood Pressure Control in Diabetes Mellitus

#117. Diabetes Mellitus: Dilated Eye Exam in Diabetic Patient

#119. Diabetes Mellitus: Urine Screening for Microalbumin or Medical Attention for Nephropathy in Diabetic Patients

#163. Diabetes Mellitus: Foot Exam

ADULT KIDNEY DISEASE MEASURES GROUP: (Formerly called (Chronic Kidney Disease)

Intent Code: G8487 Composite Code: G8495 #110. Preventive Care and Screening: Influenza Immunization

#121. Chronic Kidney Disease (CKD): Laboratory Testing (Calcium, Phosphorus, Intact Parathyroid Hormone (iPTH) and Lipid

Profile)

#122. Chronic Kidney Disease (CKD): Blood Pressure Management

#123. Chronic Kidney Disease (CKD): Plan of Care: Elevated Hemoglobin for Patients Receiving Erythropoiesis - Stimulating

Agents (ESA)

THE PREVENTIVE CARE MEASURES GROUP:

Intent Code: G8486 Composite Code: G8496 # 39. Screening or Therapy for Osteoporosis for Women Aged 65 Years and Older

# 48. Urinary Incontinence: Assessment of Presence or Absence of Urinary Incontinence in Women Aged 65 Years and Older

#110. Preventive Care and Screening: Influenza Immunization for Patients ≥ 50 Years Old

#111. Preventive Care and Screening: Pneumonia Vaccination for Patients 65 years and Older

#112. Preventive Care and Screening: Screening Mammography

#113. Preventive Care and Screening: Colorectal Cancer Screening

#128. Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up

#173. Preventive Care and Screening: Unhealthy Alcohol Use – Screening

#226. Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention (new)

CORONARY ARTERY BYPASS GRAFT (CABG) MEASURES GROUP:

Intent Code: G8544 Composite Code: G8497

# 43. Coronary Artery Bypass Graft (CABG): Use of Internal Mammary Artery (IMA) in Patients with Isolated CABG Surgery

# 44. Coronary Artery Bypass Graft (CABG): Preoperative Beta-Blocker in Patients with Isolated CABG Surgery

#164. Coronary Artery Bypass Graft (CABG): Prolonged Intubation (Ventilation)

#165. Coronary Artery Bypass Graft (CABG): Deep Sternal Wound Infection Rate

#166. Coronary Artery Bypass Graft (CABG): Stroke/Cerebrovascular Accident (CVA)

#167. Coronary Artery Bypass Graft (CABG): Postoperative Renal Insufficiency

#168. Coronary Artery Bypass Graft (CABG): Surgical Re-exploration

#169. Coronary Artery Bypass Graft (CABG): Anti-platelet Medications at Discharge

#170. Coronary Artery Bypass Graft (CABG): Beta-Blockers Administered at Discharge

#171. Coronary Artery Bypass Graft (CABG): Lipid Management and Counseling

RHEUMATOID ARTHRITIS MEASURES GROUP:

Intent Code: G8490 Composite Code: G8499 #108. Rheumatoid Arthritis (RA): Disease Modifying Anti-Rheumatic Drug (DMARD) Therapy

#176. Rheumatoid Arthritis (RA): Tuberculosis Screening

#177. Rheumatoid Arthritis (RA): Periodic Assessment of Disease Activity

#178. Rheumatoid Arthritis (RA): Functional Status Assessment

#179. Rheumatoid Arthritis (RA): Assessment and Classification of Disease Prognosis

#180. Rheumatoid Arthritis (RA): Glucocorticoid Management

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PERIOPERATIVE CARE MEASURES GROUP:

Intent Code: G8492 Composite Code: G8501 #20. Perioperative Care: Timing of Antibiotic Prophylaxis – Ordering Physician

#21. Perioperative Care: Selection of Prophylactic Antibiotic – First OR Second Generation Cephalosporin

#22. Perioperative Care: Discontinuation of Prophylactic Antibiotics (Non-Cardiac Procedures)

#23. Perioperative Care: Venous Thromboembolism (VTE) Prophylaxis (When Indicated in ALL Patients)

.

BACK PAIN MEASURES GROUP:

Intent Code: G8493 Composite Code: G8502 #148. Back Pain: Initial Visit

#149. Back Pain: Physical Exam

#150. Back Pain: Advice for Normal Activities

#151. Back Pain: Advice Against Bed Rest

HEPATITIS C MEASURES GROUP:

Intent Code: G8545 Composite Code: G8549 # 84. Hepatitis C: Ribonucleic Acid (RNA) Testing Before Initiating Treatment

# 85. Hepatitis C: HCV Genotype Testing Prior to Treatment

# 86. Hepatitis C: Antiviral Treatment Prescribed

# 87. Hepatitis C: HCV Ribonucleic Acid (RNA) Testing at Week 12 of Treatment

# 89. Hepatitis C: Counseling Regarding Risk of Alcohol Consumption

# 90. Hepatitis C: Counseling Regarding Use of Contraception Prior to Antiviral Therapy

#183. Hepatitis C: Hepatitis A Vaccination in Patients with HCV

#184. Hepatitis C: Hepatitis B Vaccination in Patients with HCV

HEART FAILURE (HF) MEASURES GROUP:

Intent Code: G8548 Composite Code: G8551 # 5. Heart Failure: Angiotensin-Converting Enzyme (ACE) Inhibitor or Angiotensin Receptor Blocker (ARB) Therapy for Left

Ventricular Systolic Dysfunction (LVSD)

# 8. Heart Failure: Beta-Blocker Therapy for Left Ventricular Systolic Dysfunction (LVSD)

#198. Heart Failure: Left Ventricular Function (LVF) Assessment

#226. Measure pair: a. Tobacco Use Assessment, b. Tobacco Cessation Intervention

CORONARY ARTERY DISEASE (CAD) MEASURES GROUP:

Intent Code: G8489 Composite Code: G8498 # 6. Coronary Artery Disease (CAD): Oral Antiplatelet Therapy Prescribed for Patients with CAD

# 197. Coronary Artery Disease (CAD): Drug Therapy for Lowering LDL-Cholesterol

#226. Measure pair: a. Tobacco Use Assessment, b. Tobacco Cessation Intervention

#242. Coronary Artery Disease (CAD): Symptom Management

ISCHEMIC VASCULAR DISEASE (IVD) MEASURES GROUP:

Intent Code: G8547 Composite Code: G8552 #201. Ischemic Vascular Disease (IVD): Blood Pressure Management Control

#204. Ischemic Vascular Disease (IVD): Use of Aspirin or Another Antithrombotic

#226. Measure pair: a. Tobacco Use Assessment, b. Tobacco Cessation Intervention

#236. Controlling High Blood Pressure (New in 2014)

#241. Ischemic Vascular Disease (IVD): Complete Lipid Panel – Low Density Lipoprotein (LDL-C) Control

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HIV/AIDS MEASURES GROUP:

Intent Code: G8491 Composite Code: G8500 # 159. HIV/AIDS: CD4+ Cell Count or CD4+ Percentage

# 160. HIV/AIDS: Pneumocystis Jiroveci Pneumonia (PCP) Prophylaxis

# 161. HIV/AIDS: Adolescent and Adult Patients with HIV/AIDS Who Are Prescribed Potent Antiretroviral Therapy

# 162. HIV/AIDS: HIV RNA Control After Six Months of Potent Antiretroviral Therapy

# 205. HIV/AIDS: Sexually Transmitted Diseases – Chlamydia and Gonorrhea Screenings

# 208. HIV/AIDS: Sexually Transmitted Diseases – Syphilis Screening

# 338: HIV Viral Load Suppression (New in 2014)

# 339: Prescription of HIV Antiretroviral Therapy (New in 2014)

# 340: HIV Medical Visit Frequency (New in 2014)

# 341: Gap in HIV Medical Visits Combined (New in 2014)

ASTHMA MEASURES GROUP

Intent Code: G8645 Composite Code: G8646

#53. Asthma: Pharmacologic Therapy

#64. Asthma: Asthma Assessment

#231. Asthma: Tobacco Use: Screening – Ambulatory Care Setting

#232. Asthma: Tobacco Use: Intervention – Ambulatory Care Setting

COPD MEASURES GROUP

Intent Code: G8898 Composite Code: G8757

#51. Chronic Obstructive Pulmonary Disease (COPD); Spirometry Evaluation

#52. Chronic Obstructive Pulmonary Disease (COPD); Bronchodilator Therapy

#110. Preventive Care and Screening: Influenza Immunization

#111. Preventive Care and Screening: Pneumonia Vaccination for Patients 65 years and Older

#226. Measure pair: a. Tobacco Use Assessment, b. Tobacco Cessation Intervention

INFLAMATORY BOWEL DISEASE (IBD) MEASURES GROUP

Intent Code: G8899 Composite Code: G8758

#269. IBD: Type, Anatomic Location and Activity All Documented

#270: IBD: Preventive Care: Steroid Sparing Therapy

#271: IBD: Preventive Care: Steroid Related Iatrogenic Injury-Bone Loss Assessment

#272. IBD: Preventive Care: Influenza Immunization

#273: IBD: Preventive Care: Pneumoccocal Immunization

#274. IBD: Screening for Latent TB Before Initiating Anti-TNF Therapy

#275. IBD: Hepatitis B Assessment Before Initiating Anti-TNF Therapy

#226. IBD: Preventive Care: Measure pair: a. Tobacco Use Assessment, b. Tobacco Cessation Intervention

SLEEP APNEA MEASURES GROUP

Intent Code: G8900 Composite Code: G8759

#276. Assessment of Sleep Symptoms

#277: Severity Assessment at Initial Diagnosis

#278: Positive airway Pressure Therapy Prescribed

#279: Assessment of Adherence to Positive Airway Pressure Therapy

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DEMENTIAL MEASURES GROUP

Intent Code: G8902 Composite Code: G8760

#280. Dementia: Staging of Dementia

#281. Dementia: Cognitive Assessment

#282. Dementia: Functional Status Assessment

#283: Dementia: Neuropsychiatric Symptom Assessment

#284. Dementia: Management of Neuropsychiatric Symptoms

#285. Dementia: Screening for Depressive Symptoms

#286. Dementia: Counseling Regarding Safety Concerns

#287 Dementia: Counseling Regarding Risks of Driving

#288. Dementia: Caregiver Education and Support

PARKINSON’S MEASURES GROUP

Intent Code:G8903 Composite Code: G8761

#289. Annual Parkinson’s Disease Diagnosis Review

#290. Psychiatric Disorders or Disturbances Assessment

#291. Cognitive Impairment of Dysfunction Assessment

#292. Querying about Sleep Disturbances

#293. Parkinson’s Disease Rehabilitative Therapy Options

#294. Parkinson’s Disease Medical and Surgical Treatment Options Reviewed

HYPERTENSION MEASURES GROUP

Intent Code:G8904 Composite Code: G8762

#295. Aspirin or Other Anti-Platelet or anti-Coagulant Therapy

#296. Complete Lipid Profile

#297. Urine Protein Test

#298. Annual Serum Creatinine Test

#299. Diabetes Documentation or Screen Test

#300. Blood Pressure Control

#301. LDL Control

#302. Counseling for Diet and Physical Activity

CARDIOVASCULAR PREVENTION MEASURES GROUP

Intent Code: Composite Code: G8763

#2. Diabetes Mellitus: Low Density Lipoprotein (LDL-C) Control in Diabetes Mellitus

#204. Ischemic Vascular Disease (IVD): Use of Aspirin or another Antithrombotic

#226. Measure pair: a. Tobacco Use Assessment, b. Tobacco Cessation Intervention

#236. Controlling High Blood Pressure

#241: Ischemic Vascular Disease (IVD): Complete Lipid Profile and LDL Control <100

#317. Preventive Care and Screening; Blood Pressure Measurement

CATARACTS MEASURES GROUP

Intent Code: G8906 Composite Code: G8764

#191. Cataracts: 20/40 or Better Visual Acuity within 90 Days Following Cataract Surgery

#192. Cataracts: Complications within 30 Days Following Cataract Surgery Requiring Additional Surgical Procedures

#303. Cataracts: Improvement in Patient’s Visual Function within 90 Days Following Cataract Surgery

#304. Cataracts: Patient Satisfaction within 90 Days Following Cataract Surgery

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ONCOLOGY MEASURES GROUP

Intent Code: G8977 Composite Code: G8953

#71. Breast Cancer: Hormonal Therapy for Stage IC – IIIC Estrogen Receptor/Progesterone Receptor (ER/PR) Positive Breast

Cancer

#72. Colon Cancer: Chemotherapy for AJCC Stage III Colon Cancer Patients

#110. Preventive Care and Screening: Influenza Immunization

#130. Documentation of Current Medications in the Medical Record

#143. Oncology: Medical and Radiation – Pain Intensity Quantified

#144. Oncology: Medical and Radiation – Plan of Care for Pain

#194. Oncology: Cancer Stage Documented

#226. Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention

TOTAL KNEE REPLACEMENT MEASURES GROUP (New in 2014)

Intent Code: G9234 Composite Code: G9233

#350. Total Knee Replacement: Shared Decision-Making: Trial of Conservative (Non-surgical) Therapy

#351. Total Knee Replacement: Venous Thromboembolic and Cardiovascular Risk Evaluation

#352. Total Knee Replacement: Preoperative Antibiotic Infusion with Proximal Tourniquet

#353. Total Knee Replacement: Identification of Implanted Prosthesis in Operative Report

GENERAL SURGERY MEASURES GROUP (New in 2014)

Intent Code: G9237 Composite Code: G9235

#354. Anastomotic Leak Intervention

#355. Unplanned Reoperation within the 30 Day Postoperative Period

#356. Unplanned Hospital Readmission within 30 Days of Principal Procedure

#357. Surgical Site Infection (SSI)

#358. Patient-Centered Surgical Risk Assessment and Communication

OPTIMIZING PATIENT EXPOSURE TO IONIZING RADIATION (OPEIR) MEASURES GROUP: (New in 2014)

Intent Code: G9238 Composite Code: G0236

#359. Optimizing Patient Exposure to Ionizing Radiation: Utilization of a Standardized Nomenclature for Computed

Tomography (CT) Imaging Description

#360. Optimizing Patient Exposure to Ionizing Radiation: Count of Potential High Dose Radiation Imaging Studies: Computed

Tomography (CT) and Cardiac Nuclear Medicine Studies

#361. Optimizing Patient Exposure to Ionizing Radiation: Reporting to a Radiation Dose Index Registry

#362. Optimizing Patient Exposure to Ionizing Radiation: Computed Tomography (CT) Images Available for Patient Follow-up

and Comparison Purposes

#363. Optimizing Patient Exposure to Ionizing Radiation: Search for Prior Computed Tomography (CT) Studies Through a

Secure, Authorized, Media-Free, Shared Archive

#364. Optimizing Patient Exposure to Ionizing Radiation: Appropriateness: Follow-up CT Imaging for Incidentally Detected

Pulmonary Nodules According to Recommended Guidelines

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ADDENDUM F

LINKS TO THE CMS WEBSITE

This page is an index of the available CMS documents that explain the PQRS program and its

requirements in detail. The titles of the documents in blue are actual links. Those documents that are

contained in a CMS Zip file are in blue and the titles and explanations of the documents included in the

Zip file are in black.

How to get Started

2014 PQRS Implementation Guide & – guidance on how to select, read and understand a

measure and outlines the reporting options available for 2012.

2014 Measures list – identifies and explains the measures used in PQRS, including available

reporting options/methods, measure developers and their contact information.

CMS DOWNLOAD:

2014 PQRS Measures List

2014 PQRS Implementation Guide

Individual Measures All of the following documents can be found by clicking on CMS DOWNLOADS

- 2014 Physician PQRS Specifications Manual for Claims and Registry Reporting of

Individual Measures – includes codes and reporting instructions

- 2014 PQRS Measure Specification Release Notes – outlines 2012 changes from the 2011

PQRS specification manual

- 2014 PQRS Quality-Data Code (QDC) Categories – table that outlines, for each measure,

each QDC that should be reported and clarifies those measures that require 2 or more QDCs to

report satisfactorily.

- 2014 PQRS Single Source Code Master – numerical listing of all codes for individual claims

and Registry measures for incorporation into billing software

CMS DOWNLOADS

2014 PQRS Individual Claims Registry Measure Specification Supporting Documents:

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Measures Groups The following manuals are available for Measures Groups and can be found in the CMS

Downloads immediately following this listing. - 2014 PQRS Measures Groups Specifications Manual – Measures groups specifications are

different from those of the individual measures that form the group and are reported in this

manual for claims and registry-based reporting.

- 2014 PQRS Measures Groups Release Notes - outlines 2014 changes from the 2013 PQRS

specification manual

- Getting Started with 2012 Measures Groups – a guide to implementing 2014 PQRS

measures groups

- 2014 Physician Quality Reporting Quality-Data Code (QDC) Categories - table that

outlines, for each measure, each QDC that should be reported and clarifies those measures that

require 2 or more QDCs to report satisfactorily.

- 2014 PQRS Measures Groups Single Source Code Master – numerical listing of all codes

for included in the measures groups for incorporation into billing software

CMS DOWNLOADS: ZIP File – Click below

2014 PQRS Measure Groups Specifications, Release Notes, Getting Started with 2014

PQRS Measures Groups, 2014 Quality-Data Code Categories, and 2014 PQRS Measures

Groups Single Source Code Master:

GROUP PRACTICE REPORTING (GPRO) - 2014 GPRO Requirements – Overview of the GPRO program

- 2014 GPRO Web Interface Reporting Made Simple

- 2014 GPRO Measures List, Specifications and Release Notes - includes codes and reporting

instructions and 2014 changes from the 2013 Measures Manual 2014 Group Practice Reporting Option (GPRO) Web Interface Narrative Measure Specifications

CMS DOWNLOADS:

Qualifed Clinical Data Registry - 2014 Clinical Data Registry Made Simple – Overview of the GPRO program

CMS DOWNLOADS

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CERTIFIED VENDOR SURVEY - 2014 Certified Vendor Survey Made Simple – Overview of the CVS program

CMS DOWNLOADS:

REGISTRY REPORTING

- Registry Reporting Made Simple – Registry reporting overview.

- 2014 Qualified Registries – Listing of Registries approved in 2013. The 2014 approved

registries should be published in the late spring/early summer 2014.

- 2014 Registry Vendor Criteria – requirements for entities to become registries

EHR Reporting

2014 EHR Reporting Made Simple 2014 EHR CQM Measure Specifications – description of date element names and codes

related to each of the 64 PQRS measures available for 2014. This version contains all the

CQMs for PQRS but only reports the EHR version specific -CQM.

2014 PQRS EHR Measure Specification RELEASE NOTES – outlines 2014 changes from

the 2013 PQRS EHR specification manual – not yet published by CMS

2014 EHR Downloadable Resource Table - not yet published by CMS

2014 EHR Downloadable Resource Table – Release Notes - not yet published by CMS

2014 – EHR Qualified Vendors – List of qualified EHR vendors for 2014

MAINTENANCE OF CERTIFICATION PROGRAM (MOCP)

Maintenance of Certification Program Incentive Made Simple

Maintenance of Certification Program Requirements

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Summary of Requirements for 2014 PQRS Incentive & Avoiding the 2016 Payment Adjustment

ADDENDUM G - INDIVIDUAL ELIGIBLE PROFESSIONALS

Reporting Period EPs Measure Type

Reporting Mechanism Criteria for Incentive Criteria to Avoid 2016 Penalty

12 months (Jan 1-Dec 31) Individual

Individual Measures Claims

Report at least 9 measures covering at least 3 NQS Domains for at least 50% of the EPs Medicare Part B FFS patients** Same as incentive

12 months (Jan 1-Dec 31) Individual

Individual Measures Claims No Incentive

Report at least 3 measures for at least 50% of the EPs Medicare Part B FFS patients**

12 months (Jan 1-Dec 31) Individual

Individual Measures

Qualified Registry

Report at least 9 measures covering at least 3 NQS Domains for at least 50% of the EPs Medicare Part B FFS patients** Same as incentive

12 months (Jan 1-Dec 31) Individual

Individual Measures

Qualified Registry No Incentive

Report at least 3 measures for at least 50% of the EPs Medicare Part B FFS patients**

12 months (Jan 1-Dec 31) Individual

Individual Measures

EHR & EHR Vendor

Report at least 9 measures covering at least 3 NQS domains Same as incentive

An EP must report at least 1 measure for which there is a Medicare patient

12 months (Jan 1-Dec 31) Individual

Measures Groups

Qualified Registry

Report at least 1 measures group, AND report each measures group for at least 20 patients, a majority of which must be Medicare Part B FFS patients Same as incentive

6 months (July 1-Dec 31) Individual

Measures Groups

Qualified Registry

Report at least 1 measures group, AND report each measures group for at least 20 patients, a majority of which must be Medicare Part B FFS patients Same as incentive

12 months (Jan 1-Dec 31) Individual

Measures Selected by Qualified Clinical Data Registry

Qualified Clinical Data Registry

Report at least 9 measures covering at least 3 NQS Domains for at least 50% of the EPs Medicare Part B FFS patients Same as incentive

Of the measures reported, the EP must report on at least 1 outcome measure

12 months (Jan 1-Dec 31) Individual

Qualified Clinical Data Registry

Qualified Clinical Data Registry No Incentive

Report at least 3 measures covering at least 1 NQS domain for at least 50% of the EPs Medicare Part B FFS patients

**EPs that report less than the required criteria may be subject to the MAV process to make certain there are no

additional measures or domains on which the EP could have reported

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Summary of Requirements for 2014 PQRS Incentive & Avoiding the 2016 Payment Adjustment

ADDENDUM H - GROUP PRACTICES PARTICIPATING IN GPRO

Reporting Period EPs

Measure Type

Reporting Mechanism Criteria for Incentive Criteria to Avoid 2016 Penalty

12 months (Jan 1-Dec 31)

Group Practice

GPRO Web Interface 25-99 EPs

Report on all measures in web interface AND Populate data fields for first 218 beneficiaries Same as Incentive

12 months (Jan 1-Dec 31)

Group Practice

GPRO Web Interface 100+ EPs

Report on all measures in web interface AND Populate data fields for first 418 beneficiaries, AND Report all CG CAHPS survey measures via certified survey vendor Same as Incentive

12 months (Jan 1-Dec 31)

Group Practice

Qualified Registry 2+ EPs

Report at least 9 measures covering at least 3 of the NQS domains for at least 50% of the GP's Medicare Part B FFS patients** Same as Incentive

12 months (Jan 1-Dec 31)

Group Practice

GPRO Qualified Registry 2+ EPs No incentive

Report at least 3 measures covering at least 1 of the NQS domains for at least 50% of the GP's Medicare Part B FFS patients**

12 months (Jan 1-Dec 31)

Group Practice

EHR & EHR Vendor 2+ EPs

Report 9 measures covering at least 3 of the NQS domains AND a GP must report on at least 1 measure for which there is Medicare patient data Same as Incentive

12 months (Jan 1-Dec 31)

Group Practice

CMS-Certified Survey Vendor 25+ EPs

Report all CG CAHPS survey measures via a CMS-certified Vendor AND report at least 6 measures covering at least 2 of the NQS domains using a qualified registry, direct or indirect HER submission, or GPRO web interface Same as Incentive

**EPs that report less than the required criteria may be subject to the MAV process to make certain there are no

additional measures or domains on which the EP could have reported