Allscripts CQS Planning for 2014 Webinar: FAQs

Allscripts CQS Planning for 2014 Webinar: FAQs

Listed below are questions asked by attendees based on the CQS Planning for 2014 Webinars, held on May 8, May 28, and May 30, 2014. Answers are provided below. This document may be updated with additional information.

CMS PQRS and VBM Program Questions

Have the 2013 PQRS eligible providers been released by CMS yet? Is that to be found on the IACS site?

The list of PQRS Eligible Professionals (EPs) can be found on CMS’ PQRS website, here:

www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-

Instruments/PQRS/Downloads/PQRS_List-of-EligibleProfessionals_022813.pdf Eligible Professionals include:

1. Medicare physicians (Doctor of Medicine, Doctor of Osteopathy, Doctor of Podiatric Medicine, Doctor of Optometry, Doctor of Oral Surgery, Doctor of Dental Medicine, Doctor of

Chiropractic)

2. Practitioners (Physician Assistant, Nurse Practitioner*, Clinical Nurse Specialist*, Certified Registered Nurse Anesthetist* (and Anesthesiologist Assistant), Certified Nurse Midwife*, Clinical Social Worker, Clinical Psychologist, Registered Dietician, Nutrition Professional, Audiologists) *Includes Advanced Practice Registered Nurse (APRN)

3. Therapists (Physical Therapist, Occupational Therapist, Qualified Speech-Language Therapist) If our organization chooses to report as a Group does that mean that none of our providers will receive the CMS payment adjustment?

Group reporting is done at the TIN level, and if reporting is successful, then all claims billed under that specific TIN will avoid the CMS payment adjustment. So in essence, Yes - all providers billing under that specific TIN would not be penalized.

To be clear, the situation is slightly more complicated for providers who bill under more than one TIN.

Mechanically, payment adjustments are applied on Medicare Part B claims at the level of a TIN or a TIN- NPI combination. If a TIN avoids the penalty at the TIN level, then all claims with that TIN on it will not be penalized. However, suppose an organization has providers who bill under multiple TINs. In such a case, providers must satisfy the reporting requirements under each TIN they use to bill CMS; otherwise providers may be penalized on claims that use the TIN that did not successfully report.

What is the actual name of CMS PQRS DSV reporting?

The full name is “EHR Data Submission Vendor,” which is often abbreviated to “DSV.” CMS has two categories of reporting from an EHR: EHR Direct, (where providers report files directly to CMS from their EHR), and EHR DSV, (where a third party – the Data Submission Vendor – extracts those files from a provider’s EHR and submits them to CMS on the provider’s behalf). CMS will refer to these (together) as “EHR-based” reporting options.

Does participation in the Comprehensive Primary Care Initiative (CPC) exempt the entire TIN from VBM and PQRS?

We recommend asking the CMS office overseeing your CPC participation for guidance on this question.

They should be able to provide authoritative answers, especially because written documentation on

CPC is currently scant. (Note: CMS now refers to CPCI as “CPC”)

With that said, with respect to the Value-Based Payment Modifier, CMS’ 2013 Medicare PFS Final Rule and 2014 Medicare PFS Final Rule both assert that the 2016 VBM (tied to 2014 reporting) will not apply to any groups (TINs) that have providers participating in CPC. This is also reflected in CMS’ “Summary of 2015 Physician Value-Bases Payment Modifier Policies,” which was published last year. (Available:

www.cms.gov/Medicare/Medicare-Fee-for-Service-

Payment/PhysicianFeedbackProgram/Downloads/CY2015ValueModifierPolicies.pdf)

For PQRS, we recommend asking the CMS office overseeing your CPC participation for guidance on the policies surrounding a CPC PQRS Waiver, (assuming it is still available in 2014). We have not seen specific 2014 documentation about these waivers, but we have seen them alluded to in various CMS presentations and on various CMS websites.

If we are an ACO, is there anything at all that we need to do outside of that for PQRS or VBM?

If providers are part of an ACO, do they fall under that submission, or separate based on their TIN?

We recommend asking the CMS office overseeing your ACO program for guidance on these questions.

They should be able to provide authoritative answers.

With that said, with respect to the Value-Based Payment Modifier, CMS’ 2013 Medicare PFS Final Rule and 2014 Medicare PFS Final Rule both assert that the 2016 VBM (tied to 2014 reporting) will not apply to any groups (TINs) that have providers participating in either the Medicare Shared Savings Program (MSSP) or Pioneer ACO. This is also reflected in CMS’ “Summary of 2015 Physician Value-Bases Payment Modifier Policies,” which was published last year. (Available:

www.cms.gov/Medicare/Medicare-Fee-for-Service-

Payment/PhysicianFeedbackProgram/Downloads/CY2015ValueModifierPolicies.pdf)

With respect to PQRS, TINs participating in the Medicare Shared Savings Program (MSSP) will receive PQRS credit for completing their ACO reporting in the GPRO Web Interface. For Pioneer ACOs, the ACO Primary TIN will receive PQRS credit for completing its ACO reporting in the Quality Measures Assessment Tool (QMAT). More information can be found in CMS’ “How to Report Once for 2014 Medicare Quality Reporting Programs” document, (available: http://www.cms.gov/Medicare/Quality- Initiatives-Patient-Assessment-Instruments/PQRS/Downloads/How-to-Report-Once-for-2014.pdf) Please note that these policies only apply to the CMS-sponsored ACO Programs: the Medicare Shared Savings Program and the Pioneer ACO program. Groups participating in commercial or other ACO programs are still required to report in order to satisfy PQRS and the VBM.

Where can I get more information about the CAHPS survey, specifically regarding CMS paying for it for large TINs?

You can find more information at CMS’ “CMS-Certified Survey Vendor” page here:

www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/CMS-Certified- Survey-Vendor.html

CMS also has a document titled “CMS-Certified Survey Vendor Reporting Made Simple,” available here:

www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-

Instruments/PQRS/Downloads/2014PQRS_CMS-CertifiedSurveyVendorMadeSimple_F01-21- 2014.pdf

Regarding the cost of CAHPS being covered by CMS, the CMS website (link above) notes:

Unchanged for 2014 is the requirement of group practices of 100 or more EPs reporting via GPRO

Web Interface to require patients complete the 12 CAHPS for PQRS summary survey modules on

behalf of their experience and care within that group practice. CMS will continue to bear the cost of

the CAHPS for PQRS summary survey modules for this specific group.

CMS Self-Nomination Questions

Please elaborate on Self-Nomination: Where and how is it done, for what stage, does the provider do themselves or does IS/IT, etc.?

Please see CMS’ Self-Nomination website for complete information: www.cms.gov/Medicare/Medicare- Fee-for-Service-Payment/PhysicianFeedbackProgram/Self-Nomination-Registration.html

Additionally, your organization may want to review a recent CMS National Provider Call, held in April, on the Self-Nomination Process:

www.cms.gov/Outreach-and-Education/Outreach/NPC/National-Provider-Calls-and-Events-Items/2014- 04-10-PQRS-NPC.html

Every TIN with 2 or more EPs that wishes to report via a Group Practice Reporting Option (GPRO) must Self-Nominate before September 30. If a TIN is not reporting via GPRO, Self-Nomination is not

required. Typically, only one individual from an organization is needed to Self-Nominate on behalf of a given TIN; this is usually an Administrator but can vary by organization, depending on the organizational structure. But this is not something the providers need to do themselves. The process is two-fold: first, the individual must obtain a specific IACS Account (the “PV-PQRS Group Security Official” role), and once those credentials are obtained, the individual can then log into a separate CMS Self-Nomination Portal and complete the Self-Nomination. If an individual obtained this IACS role for Self-Nomination last year, in most cases s/he should be able to repeat the Self-Nomination process this year. Please see the CMS website for instructions on how to obtain this IACS role and complete the Self-Nomination.

As the Self-Nomination process has two steps, we strongly recommend having an individual in your organization obtain the proper IACS account (i.e., Step 1) as soon as possible. The Self-Nomination (Step 2) can wait until September, but obtaining the IACS account is the most onerous part of this process.

How do you self-nominate if you are an organization with multiple sites that have multiple TINs?

Some TINs in our organization may have 25+ providers, and a few may not.

Each TIN must report PQRS in a way that meets CMS requirements, based on the TIN’s size. If a TIN has 25 or more EPs, the TIN can report via the GPRO Web Interface (or via another method). If a TIN has fewer than 25 EPs, it can report via GPRO Registry or a GPRO EHR DSV, or have the providers report as Individuals. Once an organization determines how each TIN is going to report, the

organization must complete the Self-Nomination process for each TIN that wishes to report as a GPRO.

If a TIN is not reporting as a GPRO, Self-Nomination is not required.

If an organization has multiple TINs that wish to report as a GPRO, each TIN must self-nominate and report separately, by TIN. In such cases, a single person within an organization can usually acquire the requisite IACS role to self-nominate for more than one TIN. In that case, please consult CMS to ensure that the individual has the right credentials to do so. We strongly recommend starting the IACS process now in order to ensure that an individual in your organization can complete the self-nomination for any/all of your TINs. You can find more information, including contact information for CMS, at:

www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PhysicianFeedbackProgram/Self- Nomination-Registration.html

Questions about the GPRO Web Reporting Tool & Web Interface Reporting

What are the 22 GPRO Web Interface measures?

A list of the 22 measures, divided into 7 disease modules, is provided at the end of this document as an Appendix. For more information about these measures, including their specifications, please see CMS’

GPRO Web Interface page: www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment- Instruments/PQRS/GPRO_Web_Interface.html

Is the GPRO Web Reporting Tool already something we have, or something that needs to be purchased?

Contractually, the GPRO Web Reporting Tool is included with the Patient-Centered Care (PCC)

Channel. It does not need to be purchased separately. Functionally, the Tool exists outside of the PCC Channel, and it will be provided to groups who will use it at the end of the year, (i.e., once CMS

releases its updated XML specifications).

Will the CQS GPRO Web Reporting Tool allow us to see our data throughout the year or will we have to wait until the end of the year to view our data?

All 22 of the CMS GPRO Web Interface measures are contained within the CQS PCC channel, so you will be able to monitor your group’s performance on these measures using the PCC channel throughout the year. This will be a superset of the actual patients you end up reporting to CMS, since PCC includes all patients and CMS provides its patient sample for reporting at the end of the year.

Will CQS be able to extract data from EHRs other than Allscripts if we choose to report via the GPRO Web Interface?

No. CQS currently can only extract data from the Allscripts TouchWorks (formerly Enterprise) EHR.

Does the XML file include a sample size taken from the entire group?

The XML file downloaded from the GPRO Web Interface portal will contain the entire patient sample assigned to your group. During the year, CMS will sample patients from your organization to be reported on via the GPRO Web Interface. When the Web Interface portal opens in Q1 2015, the Web Interface will contain the entire sample of patients that must be reported. Organizations can download this patient list (in its entirety, for all measures) as an XML file from the Web Interface.

Does the CQS GPRO Web Reporting Tool also extract Claims data if our CQS is interfaced with our PM system or will it only pull the TouchWorks EHR data?

The GPRO Web Reporting Tool extracts data from your CQS database. So the Tool will utilize the data available, including PM and/or EHR data within CQS, to populate the CMS Patient and Patient

Discharge XML files to be uploaded to the CMS GPRO Web Interface portal.

Q: How do you know that the 8 clients who used the GPRO Web Reporting Tool reported successfully? Is there a way for me to check whether my organization reported successfully for 2013?

We know that those 8 clients were successful because they completed the reporting process, (which is the requirement for “success,” unlike Registry or DSV reporting). Unfortunately there is not a way at the moment to determine whether 2013 Registry or DSV reporting was successful; CMS will publish feedback reports and pay incentives this Fall, as it has in past years. GPRO Web Interface reporting is different from Registry or EHR DSV reporting in that “successful reporting” simply requires completion of the Web Interface, whereas Registry and DSV submissions are evaluated to determine success. For 2013, a successful Registry or DSV submission required an 80% reporting rate, and so CMS is evaluating submissions against that threshold. But for GPRO Web Interface, all that is required is filling in the data within the Web Interface for the assigned patient sample.

Were any of the 8 clients that utilized the CQS GPRO Web Reporting Tool in 2013 audited, to

your knowledge?

One of our clients participating in the Medicare Shared Savings Program, which reported ACO Quality Measures using the CQS GPRO Web Reporting Tool, advised us that their organization was audited by CMS following completion of reporting. This client provided the following information:

“We evaluate whether the new products/solution can do the job easier or better. It was easier and better. [Our organization] was also selected for a quality measure audit…I was able to complete the quality audit in 2 days. It was not difficult at all…I found zero discrepancies in the data downloaded from the PCC channel and subsequently uploaded to the CMS GPRO Web Interface. I was able to submit 100% of the requested documentation to CMS. We have not been notified of our audit results, but I expect a favorable result. Let everyone know on your team what a great experience it was to be a client.”

Questions about Reporting Options for TINs with <25 eligible providers

Our organization only has 3 providers. What is the effect for small practices that don’t qualify to report via the GPRO method since CQS no longer supports Registry?

If we have 10 or less providers under 1 TIN, does TeamPraxis not report data at all? Do we report individually instead of a group without the help of TeamPraxis?

TINs must have at least 25 Eligible Professionals (EPs) in order to report via the GPRO Web Interface method. If a TIN has fewer than 25 EPs, those EPs must report via a different reporting option. One such option might be the Allscripts PQRS GPRO DSV reporting option, (separate from CQS), which will be announced by Allscripts in the near future this summer. Please keep in mind that if a TIN has 10 or more EPs, that TIN must report as a GPRO (or have 50% of the EPs report as individuals) in order to satisfy the VBM requirements. TINs with fewer than 2-9 EPs may report as a GPRO or have the providers report as Individuals. TINs with only 1 EP must have that provider report as an Individual.

My TIN has only 9 providers. I am still be able to submit as a GPRO, correct?

Yes. Any TIN with 2 or more eligible professionals (EPs) can self-nominate and report as a GPRO. For a TIN with between 2-24 providers, that TIN may self-nominate for either the GPRO Registry or GPRO EHR DSV reporting options.

Would our organization have to self-nominate if we only have 3 physicians in our practice since we will still be able to do Claims-based reporting?

No. If those 3 providers are reporting as individuals, (which Claims-based reporting is), then no self- nomination is required. Self-nomination is only required for TINs reporting as via a Group Practice Reporting Option (GPRO) – either GPRO Web Interface, GPRO Registry or GPRO EHR (Direct or DSV).

If providers are reporting as Individuals, no self-nomination is required.

Questions about Other CMS Programs

Did you say there was a new date for Stage 2? Or was that only for those who are not 11.4.1?

No, there is not a new date for MU Stage 2. CMS announced a “Proposed Rule” on May 20, 2014 that would provide flexibility to providers who have not received a “2014 Edition” ONC-Certified EHR in time to demonstrate Meaningful Use in 2014. As of the date of this Q&A document, that Rule is not yet final, so it is not yet an official CMS policy. Should that Rule be finalized, it would not change anything for providers who have a functional “2014 Edition” ONC-Certified EHR (i.e., TouchWorks 11.4.1). It would, however, provide alternative options to providers who were unable to get the new EHR version from their vendor in time to demonstrate Meaningful Use in 2014. So all that to say, IF this Proposed Rule becomes finalized, it will only impact organizations that did not receive a functional “2014 Edition”

ONC-Certified EHR in time to show Meaningful Use this year. If your organization upgrades to

TouchWorks 11.4.1 in time to show Meaningful Use this year, it does not impact you.

General CQS Questions

Will there be a charge for upgrades?

Upgrades are covered under your SMA fees with no additional cost.

Appendix: List of CMS PQRS GPRO Web Interface Measures

GPRO #  Measure Title  Alternative Measure #s 

  Care Coordination/Patient Safety (CARE) Measures (2 Measures)

CARE‐1  Medication Reconciliation  PQRS #46, ACO 12, NQF 0097

CARE‐2  Falls: Screening for Future Fall Risk PQRS #318, ACO 13, NQF 0101, CMS139v2   Coronary Artery Disease (CAD) Disease Module (2 Components of 1 Composite Measure) 

CAD‐2  CAD Composite (All or Nothing Scoring): Coronary Artery  Disease (CAD): Lipid Control 

PQRS #197, ACO 32, NQF 0074 CAD‐7  CAD Composite (All or Nothing Scoring): Coronary Artery 

Disease: Angiotensin‐Converting Enzyme (ACE) Inhibitor or  Angiotensin Receptor Blocker (ARB) Therapy ‐ Diabetes or  Left Ventricular Systolic Dysfunction (LVEF <40%) 

PQRS #118, ACO 33, NQF 0066

  Diabetes Mellitus (DM) Disease Module (1 Individual Measure and 1 Composite Measure) 

DM‐2  Diabetes: Hemoglobin A1c Poor Control PQRS #1, ACO 27, NQF 0059, CMS122v2   Diabetes Composite: Optimal Diabetes Care (5 Components of 1 Composite Measure) 

DM‐13  Diabetes Composite (All or Nothing Scoring): Diabetes  Mellitus: High Blood Pressure Control 

PQRS #319, ACO 24, NQF 0729 DM‐14  Diabetes Composite (All or Nothing Scoring): Diabetes 

Mellitus: Low Density Lipoprotein (LDL‐C) Control 

PQRS #319, ACO 23, NQF 0729 DM‐15  Diabetes Composite (All or Nothing Scoring): Diabetes 

Mellitus: Hemoglobin A1c Control (< 8%) 

PQRS #319, ACO 22, NQF 0729 DM‐16  Diabetes Composite (All or Nothing Scoring): Diabetes 

Mellitus: Daily Aspirin or Antiplatelet Medication Use for  Patients with Diabetes and Ischemic Vascular Disease 

PQRS #319, ACO 26, NQF 0729

DM‐17  Diabetes Composite (All or Nothing Scoring): Diabetes  Mellitus: Tobacco Non‐Use 

PQRS  #319, ACO 25, NQF 0729   Hypertension (HTN) Disease Module (1 Measure)

HF‐6  Heart Failure (HF): Beta‐Blocker Therapy for Left  Ventricular Systolic Dysfunction (LVSD) 

PQRS #8, ACO 31, NQF 0083, CMS144v2   Ischemic Vascular Disease (IVD) Disease Module (2 Measures)

IVD‐1  Ischemic Vascular Disease (IVD): Complete Lipid Panel and  LDL Control 

PQRS #241, ACO 29, NQF 0075,  CMS182v2/3 

IVD‐2  Ischemic Vascular Disease (IVD): Use of Aspirin or Another  Antithrombotic 

PQRS #204, ACO 30, NQF 0068, CMS164v2   Preventive (PREV) Care Measures (8 Measures – Individually Sampled)

PREV‐5  Breast Cancer Screening  PQRS #112, ACO 20, CMS125v2

PREV‐6  Colorectal Cancer Screening  PQRS #113, ACO 19, NQF 0034, CMS130v2 PREV‐7  Preventive Care and Screening: Influenza Immunization PQRS #110, ACO 14, NQF 0041

PREV‐8  Pneumonia Vaccination Status for Older Adults PQRS #111, ACO 15, NQF 0043, CMS127v2 PREV‐9  Preventive Care and Screening: Body Mass Index (BMI) 

Screening and Follow‐Up 

PQRS #128, ACO 16, NQF 0421, CMS69v2 PREV‐10  Preventive Care and Screening: Tobacco Use: Screening 

and Cessation Intervention 

PQRS #226, ACO 17, NQF 0028, CMS138v2 PREV‐11  Preventive Care and Screening: Screening for High Blood 

Pressure and Follow‐Up Documented 

PQRS #317, ACO 21, CMS22v2 PREV‐12  Preventive  Care  and  Screening:  Screening  for  Clinical 

Depression and Follow‐Up Plan 

PQRS #134, ACO 18, NQF 0418, CMS2v3