Toward Accountable Payment

The 'fiscal cliff' deal's unexpected impact on physician P4P

by Rob Lazerow

As we have discussed in past blog posts and in The field guide to Medicare payment innovation, pay-for-performance programs have rapidly become a new reality for providers across the care continuum. Regardless of their future plans for bundled payments or ACOs, providers are now facing CMS’s mandatory Medicare contingent payment programs. 

Looking beyond Medicare’s high-profile Hospital Value-Based Purchasing Program, physicians nationwide must contend with the Physician Quality Reporting System (PQRS). PQRS currently offers physicians a 0.5% reimbursement bonus for voluntarily submitting performance data. Starting in 2015, however, CMS will penalize physicians who do not participate through a 1.5% reimbursement withhold.

In a somewhat unexpected development, Congress’ recent “fiscal cliff” deal (the American Taxpayer Relief Act of 2012), includes provisions that meaningfully change the PQRS by offering physicians new flexibility in how they can satisfy the reporting requirements. As a result, physicians—both independent and employed—will need to determine their preferred path for meeting the Medicare quality reporting mandate.

Clinical data registries may satisfy PQRS reporting

According to the “fiscal cliff” deal, physicians (and other eligible professions included in the PQRS) will gain a new option for meeting PQRS reporting requirements beginning in 2014—participate in a “qualified” clinical data registry. The new provision was championed by specialty societies, several of which run registries with specialty-specific metrics suited to the needs of their members.

This new policy may ultimately increase physician participation in PQRS, particularly among specialists. Specialists have long raised concerns that PQRS measures are not relevant to the type of care they provide and are overly burdensome to report. The move to clinical data registries may address these two concerns.

Next up: Defining “qualified” clinical data registries

While the ability to satisfy reporting requirements by participating in a clinical data registry may be appealing at first glance, there are still plenty of open questions. Most importantly, the Secretary of HHS must define the requirements for becoming a “qualified” clinical data registry.

The new law offers four specific considerations to guide development of the requirements:

  • Transparency of data elements, risk models, and measures
  • Submission of data with respect to multiple payers
  • Provision of timely performance reports at the individual participant level
  • Support for quality improvement initiatives for participants

We will continue to monitor implementation of the new clinical data registry provisions and report any key details and implications in future Toward Accountable Payment posts.

Additional Resources

Learn more about Congress’s “fiscal cliff” deal by accessing our on-demand webconference, "Beyond the 'Fiscal Cliff'." As always, please feel free to call or email me with any questions or comments.