There is not a lot of time left for medical practices to report for PQRS. The March 31 deadline is the last in a group of five, two of which have already passed. Failing to register by the end of this month could mean facing a penalty of up to 6% for Medicare reimbursements. For practices that are ready to report PQRS measures sooner, the nearer deadline is March 18, 2016 at 05:00 pm ET. Reporting within that date would mean avoidance of a 2.0% penalty.

The Financial Risk In 2015

The ideal scenario for eligible providers and GPRO group practices is to avoid the maximum penalty while earning the maximum incentive available to them under the PQRS and the Value Based Modifier (VBM) programs. Together, these two expose about 4-6% of eligible allowed Medicare Part B FFS charges.

PQRS Penalty

2015 was the first year that they removed any incentives for participating in PQRS programs. There is instead an automatic 2% penalty for failing to participate in the reporting of PQRS measures by eligible solo providers, and GPRO practices.

Value-Based Modifier Penalty and Quality Tiering

Starting with the 2015 PQRS reporting period, the VBM will apply to all groups of physicians and physician groups. This modifier checks both PQRS quality data and Medicare cost data when arriving at the overall score for a provider. The VBM program is budget-neutral, and provides upward payment adjustment to providers who perform demonstrably well, as well as a downward adjustment to those that lag, and a neutral payment adjustment to those that figure in the middle.

VBM adjustments will add to PQRS, and be automatically applied to all providers and group practices who don’t successfully report to PQRS. For these people, the VBM payment adjustment will be applied via quality tiering. Additionally, for the 2015 reporting period, solo practices and groups of 2-9 providers will be exempted from downward adjustments, while leaving them eligible for neutral or upward adjustments.

Ten or more providers can receive any of the three types of adjustment – neutral, downward, or upward. If receiving an upward adjustment, groups and solo practitioners will be eligible for an extra +1.0x payment adjustment as long as their beneficiary score falls within the top 25% of all the risk scores measured nationwide.

Avoid Both Penalties

EPs will have several options within PQRS reporting participation to avoid PQRS and VBM automatic penalties. In 2015, CAHPS for PQRS survey was mandatory for groups comprising over 100 or more EPs, and was optional for groups made up of 2-9 EPs. At the lower end, group can choose if or not they wish to include the results of CAHPS for PQRS survey with the calculation of their value modifier for 2017.

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