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What is the difference between claims-based and registry-based reporting?

Registry based reporting differs significantly from claims based reporting in two important ways. First, registry reporting is based on the aggregate of the patient population and not by the individual patient or claim. Second, as a registry, CINA is responsible for calculating and reporting both the numerators and denominators for each measure. This information is used to determine the provider’s reporting percentage and performance percentage. Bonus payments are determined solely on the reporting percentage.

In previous years, many providers were unsuccessful with claims-based reporting. This was due to a myriad of factors, including discrepancies between CMS’ calculation of denominators and numerators based solely on claims billing, clearinghouse and intermediary errors in recognizing and authorizing the required CPT2 codes, and billing systems not designed to handle CPT2 codes. These problems are virtually non-issues with registry-based reporting.

 

I understand there are different types of Registries, please explain.

There are 3 types of registries:
Electronic Registry (CINA PQRI Registry)—data is queried electronically requiring no manual data entry by the practice. Generally practices with an EMR are best suited for electronic registries, but there are occasions where a practice without an EMR is accessible electronically.
Manual Data Entry Registry—generally web based, these registries require the practice to enter all data manually. A manual registry works well for practices with small number of providers but is generally not preferred for medium to large practices.
EMR Registry—CMS qualified 7 EMR systems for reporting directly from the EMR in 2010. The number of measures for which any give EMR can report may be limited. You will find a list of qualified EMR Registries on the CMS PQRI website.

 

What reporting methodologies can registry utilize?

Qualified registries are allowed to report using two methodologies:

• Measure Groups, used primarily by registries, require manual data entry on a specified set of measures on either 15 (half year reporting) or 30 (full year reporting) consecutive patients. Of the patients reported, at least two must be Medicare patients.
• Individual Measure Reporting, used primarily by registries with the ability to abstract data electronically, requires at least three measures to be reported on 80% of the eligible patient population for those measures.

The only registry option that CINA will offer will be Individual Measure Reporting since data abstraction is done electronically.

 

Do I need an EMR to be able to file PQRI?

Not necessarily, but if you do not have an EMR you must be attempting to report using the GCodes (CPT2 codes used for reporting PQRI measures). However, the benefit of using a registry such as the CINA PQRI Registry is that you can input the GCodes “after the fact”—you can get credit for reporting even if the code does not go out with the claim.

 

How many patients and measures must I report on to receive the incentive payment?

There are several different reporting options that have variable reporting criteria. The CINA Registry only reports using the Individual Measure option which requires reporting on at least 80% of the patients eligible for the measure for at least 3 measures. For more information about other reporting options, refer to the CMS PQRI website.

 

What constitutes successful PQRI reporting?

Incentive bonus payments are based solely on the reporting percentage. Although no registry can guarantee that a provider will receive a bonus payment, based on complying with the existing registry reporting criteria, CINA anticipates no problems with accurate reporting.

 

How is the bonus payment calculated?

Bonus payments are calculated at 2% of total Medicare eligible claims. Only Fee for Service reimbursement (billed from the physician fee schedule) is eligible for inclusion. Medicare Advantage plans are not eligible and practices should not factor that reimbursement in when calculating anticipated bonus payments.

 

Does CMS monitor the registry reporting process?

As a registry, CINA must maintain a data validation strategy that confirms both accurate and complete data is extracted and reported to CMS. While CMS has the right to audit registry reporting processes, there currently is no defined process established by which CMS will challenge or audit the registry reporting process. CMS has indicated that a gross discrepancy between the number of patients reported and billed claims could trigger some type of audit process. However, to date, this process and the applicable rules have not been published.

 

What does CMS do with the submitted data?

There are currently two reports generated by CMS for each provider: 1) The Reporting Rate shows the number of eligible patients (denominator) for each measure and the number of reporting instances (numerator). The Reporting Rate determines bonus payment and is based completely on reporting, not performance The second report is the Performance Rate, which benchmarks the provider against the 25th, 50th, and 75th percentile of all providers reporting for each measure. In addition to the CMS reports, CINA will provide benchmarking reports for both individual providers and the practice as a whole for all measures reported.

 

Can providers appeal reporting feedback?

There is no indication that there will be any type of appeal process for providers if they disagree with the reporting feedback.

Are there any incentives for e-prescribing and can CINA report this?

Practices now have the ability to receive 2% of allowable Part B billings for reporting e-prescribing on at least 50% of their eligible population in 2009. This is in addition to the 2% bonus for PQRI reporting. CINA is able to report e-prescribing in 2010 as a qualified eRx registry.

 

What are the costs associated with PQRI Reporting through CINA?
Using the CINA Registry for reporting carries 2 costs:  1) a one-time installation fee to cover the cost of the software, hardware, data mapping and measure testing;  2) an annual PQRI submission fee for each provider for whom data is reported. Please contact us to discuss how we can help your practice and/or organization.

What is the implementation time frame for the CINA Quality Suite?
Providers using an EMR we are currently working with can expect a timeframe of 8-10 weeks from the time a contract is received, assuming no significant hold-ups to the installation on the part of the practice. Please ask a CINA representative for more information.

What is the deadline to sign a contract with CINA for 2010 PQRI Reporting?
CINA suggests you return a signed contract, accompanied with the implementation fee, by September 30, 2010 to insure submission of your PQRI data for 2010.

Who can report to PQRI?
Any provider that is billing under their own NPI to Medicare Part B is probably eligible to participate in PQRI.  Physicians and midlevel providers are included.  To see a full list of eligible providers, go to the CMS website: www.cms.gov/pqri

Will providers that are new to my practice or leave mid-year be able to participate in PQRI reporting?

Yes. As long as CINA reports successfully on behalf of the provider, it does not matter whether the provider is affiliated with the practice at the time of reporting.  Each provider does need to sign a Provider Participation Form in order for CINA to report their data to CMS so it is beneficial to get these forms signed as early as possible.  Likewise, if a provider was affiliated with another group at some point during the year, both groups can report on that provider since the submission to CMS is done at the TIN/NPI level.

How do the measures get selected?
CINA will work with practice to determine at least 3 measures for filing based on the data the practice has in the EMR and the specialty. 

 

 

For a full list of FAQ’s, go to the CMS website at www.cms.gov/pqri.