Not So Fast: New quality provisions aren’t ready for implementation, medical groups say

The legislation, however, does include an alternate pathway to meet the PQRI standards, through participation in an “enhanced” Part IV of the American Board of Otolaryngology’s Maintenance of Certification Program. MOC participants will be required to complete a Part IV activity relating to performance in practice every five years in the ten-year MOC cycle. The requirement for an enhanced Part IV means that the participant must perform a Part IV activity every two years. “We are working diligently to finalize our Part IV program in the next year or two,” said Robert Miller, MD, MBA, executive director of the American Board of Otolaryngology and editor of ENT Today. “Clearly, this option will be advantageous to MOC participants.”

Ironing Out the Details

The act, signed into law on March 23, makes some improvements to PQRI, Bennett noted; the details, however, are unclear. The law requires that Medicare establish an informal appeals process for physicians who believe they should have gotten a PQRI bonus. Currently, physicians have no recourse when they disagree with CMS’ determination that they did not successfully report quality measures.

The MGMA is pressing for quarterly, if not monthly, feedback reports to physicians. Physicians participating in the 2010 PQRI, for example, haven’t received feedback on whether they successfully reported measures in 2009, so they could be unknowingly making the same reporting mistakes, Bennett said.

Physician groups also find the law’s creation of a value-based payment modifier under the physician fee schedule troubling. The modifier will provide for a differential payment to physicians or groups of physicians based on the quality of care compared to its cost during a performance period, Bennett explained. Cost is measured by resources used. “The overall goal is to provide a financial incentive to doctors to report on quality measures and to not overutilize,” he said.

According to Bennett and Hedstrom, the fundamental building blocks of the initiative haven’t been developed yet, and the time frame is too tight. CMS, for example, is still working on how to group care for a patient into an episode in order to measure resource use within that episode, Hedstrom said. The agency will also have to determine which physician the resource use is attributable to, Bennett said. For example, if a doctor asks another physician for a patient consultation, who is the consultation attributed to—the doctor who ordered it or the one who performed it?