As March 31st looms on the horizon, we've been hard at work shepherding our PQRS Registry participants towards successful quality reporting. That means we spend a lot of time analyzing data, reviewing measure selections, and answering basic questions about the PQRS program. One consistent pattern we’ve seen is confusion between 2016’s PQRS reporting program and 2017’s MIPS Quality reporting program. It’s understandable: in 2017 MIPS Quality will completely replace PQRS. To help alleviate the confusion, I’ve gathered together 8 main differences between PQRS and the MIPS Quality program.
1. Bonus and Penalty Structure:
PQRS is a stand-alone program. In 2016, failure to satisfactorily report PQRS results in an automatic 2% penalty to your 2018 Medicare billings. But, PQRS also overlaps with a variety of other CMS programs like MAV, VM, and MU. Most of these other programs also carry their own penalty or bonus, so figuring out exactly what’s at stake for one reporting period is complicated. For 2017, CMS has attempted to streamline these various programs. The 2017 MIPS Quality program is actually one part of the bigger MIPS program. So, participants in the MIPS Quality program will only have one overall MIPS penalty or bonus, rather than separate bonuses or penalties for each distinct program.
2. Who Is Required to Report Quality Measures:
For PQRS, everyone that had submitted a bill on a patient to Medicare Part B Fee For Service in 2016 needed to report quality measures if they wanted to avoid the automatic 2% penalty. For MIPS Quality reporting, not everyone that bills Medicare Part B Fee For Service will need to report. For example, the low threshold exception exempts participants who have less than $30,000 worth of Medicare Part B Fee For Service bills, or who have less than 100 Medicare Part B Fee For Service patients. Additionally, certain types of Advanced Payment Models are exempted from MIPS Quality reporting. Finally, participation in a certain other types of Advanced Payment Models means that participants can skip MIPS reporting - including MIPS Quality reporting - altogether.
3. Reporting Time Period:
To avoid an automatic penalty in PQRS, the program required that quality measures be reported for the full performance year, January 1st to December 31st. With MIPS - at least for 2017 - participants can avoid an automatic penalty as long as they report on something for some time period. Though, participants should keep in mind that this relaxed time frame for reporting period will change in 2018 and beyond, eventually once again requiring a full year's reporting.
4. Reporting Population:
PQRS requires that participants report on at least 50% of the Medicare Part B Fee For Service patients who qualify for the chosen quality measures. MIPS requires that participants report on at least 50% of all patients who qualify for the chosen quality measures, regardless of payer.
5. Number of Quality Measures Required to Report:
PQRS requires participants to report at least 9 quality measures. MIPS requires participants to report on 6 quality measures.
6. Structure of Required Quality Measures:
PQRS requires that the quality measures participants choose to report span across 3 domains, which are like categories of effective healthcare. MIPS only requires quality measures to be reported, they do not have to be chosen from any specific categories.
7. Cross-Cutting Measures vs. Outcomes Measures:
PQRS requires that the quality measures reported by participants include one cross-cutting measure, unless a special exception applies. MIPS does not require cross-cutting measures, but rather requests that the quality measures reported by participants include one outcomes measure.
8. Measure Groups:
PQRS allowed participants to utilize measure groups reporting as an alternative way to satisfactorily report quality measures; MIPS does not allow for measure groups reporting.
And, finally, one bonus difference plus similarity...
Still a Four Letter Word, Just a Different One:
PQRS means the “Physician Quality Reporting System” and MIPS is the “Merit-Based Incentive Payment System.” Thus far, despite efforts by CMS to ease the burden of quality reporting, both programs have caused frustration, anxiety and struggle for many of those involved.