Medicare to Cut Payments for Not Meeting Reporting Requirements

By Paula E. Hartman-Stein, Ph.D.
November 7, 2012

Medicare to Cut Payments for Not Meeting Reporting RequirementsApathy is turning into urgency as clini-cians who bill under Medicare learn that financial penalties are slated for 2015 for non-compliance in the Physicians Quality Reporting System (PQRS) beginning January 2013.

According to the website on PQRS from the Center for Medicare and Medicaid Services (CMS), “Beginning in 2015, if the eligible profes-sional or group prac-tice does not satisfactorily submit data on Physician Quality Reporting System quality measures, a 1.5 percent payment adjustment will apply. To avoid the 2015 adjustment, an eligible professional must satisfactorily report Physician Quality Reporting System quality measures during the 2013 reporting period (Jan. 1-Dec. 31, 2013).”

Anita Somplasky, director of health care quality improvement for the West Virginia Medical Institute, clarified how the sanction will work: “The penalty for non-participation in 2013 will be an automatic 1.5 percent reduction on each payment in 2015.”

Peter Kanaris, Ph.D., coordinator of public education of the APA’s Public Education Campaign in New York and member at large of the executive committee of the New York State Psychological Association (NYSPA), said, “Hearing about the penalties for not participating in PQRS at a recent Medicare workshop sponsored by NYSPA took me and the entire group by complete surprise.”

In a phone interview, Kanaris said he had been aware of PQRS, but he and other psychologists at the workshop lacked sufficient education about the program. “Knowing there will be a penalty provides sufficient stimulation to get me to move myself and participate in the pro-gram,” he said. “I am more responsive to the stick rather than to the carrot.”

PQRS is a reporting program that has been providing a small financial incentive to eligible Medicare providers who submit data on specified screening measures on Medicare claim forms. Psychologists have been eligible to participate since 2008.

In 2012 CMS suggested that clinicians report on at least three screening measures, but as long as at least one measure has been reported in 50 percent of the applicable Medicare Part B fee-for-service patients, the health care professional was eligible for a bonus payment of 0.5 percent to be distributed in the fall of the subsequent year. Clinicians who participated in 2011 received their bonus checks in mid-October 2012.

Psychologists had 10 measures avail- able for reporting in 2012 under the individual claims reporting system. Measures can also be reported through a registry system that requires a fee to join. Regardless of which system a health care provider chooses, CMS suggests that clinicians decide that the screening areas they choose fit best with the particular patient population they serve.

According to a recent trends report from CMS, fewer than 200,000 eligible providers out of more than 600,000 participated in PQRS in 2010. Emergency physicians had the largest representation among all specialties and also had a high rate of participation (65 percent). The CMS report said, “Hospital-based practices most likely have processes in place to capture clinical data accurately, therefore allowing quicker uptake of reporting quality measure data.”

Of the 10 specialties listed in the CMS report, psychologists fit into “Other Eligible Professionals.” Only 17 percent of eligible providers participated in 2010.

Alice Randolph, Ed.D., MSCP, owner of Psychological Transitions in Port Clinton, Ohio, a company that provides psychological services in long term care facilities in four states, said, “I have made it a requirement for my 20 employees to participate in PQRS because it is worthwhile to change the way they think by rewarding them. This is very positive on the part of CMS.”

Randolph said after studying the areas that psychologists could screen under PQRS she chose elder abuse, depression and tobacco use. “These are very effective things to ask in a psychological assessment,” she said. “I’m not asking the practitioners to do any- thing that is alien to a clinical interview.”

According to Randolph, asking questions of nursing home patients about abuse elicited content for psychotherapy and helped to explain why adjustment was not going well or the possible reason for negative reactions of some female patients to male nursing assistants.

“There is a whole lot more Post-Traumatic Stress Disorder than we realize. The elder abuse screen has four or five questions that can generate painful memories. That area of screening has been the most surprising and productive.”

Randolph said she was audited on her use of PQRS measures two times by Quality Insights of Pennsylvania, the agency contracted to develop psychological measures, and she had no problems.

“I have found that by creating a form you don’t leave it up to a clinician’s memory. If you are organized and have a form for it. It is no big deal.” Mary Lewis, Ph.D., president of Psychologists in Long-Term Care and psychologist with Senior Life Consultants in Columbus, Ohio, said, “I have not ever officially participated in PQRS but I have been informally documenting measures on my clientele.

“I think it has helped me tremendously because it standardized my assessment more than it used to be. It makes me catch things that I might not have asked.”

Randolph said the most challenging part of participating in PQRS is going through the pages of measures and finding those applicable to psychology.

“I found the instructional material to be cumbersome, convoluted. I waited till New Year’s Eve to wade through the measures. It took fortitude to figure it out.”

As of press time, the measures available for next year are not yet available. The screening measures are tied to the Current Procedural Terminology (CPT) codes that the AMA published in mid-October. Somplasky said she expects CMS to publish them very soon.

Kanaris thinks psychologists’ participation will increase if information is given in clear terms. “We are educable,” he said. A webpage dedicated to all the latest news on PQRS is available on the CMS website at Information from APA is also available through reim- bursement/improvement/pqri-faq.aspx

Paula E. Hartman-Stein, Ph.D., is a clinical geropsychologist who was chair of the Psychology and Social Work Expert Work Group to develop quality measures for the Physicians Quality Reporting Initiative in 2007 and co-chair of the Psychology Work Group in 2008. She is planning a national webinar on PQRS 2013through her compa- ny in early December. It was at a workshop she conducted that NYSPA members learned of the coming penalties. Her website is

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