Engage
For hospitalists, the first order of business should be ensuring that your group is participating in the Physician Quality Reporting System (PQRS) and receiving the current 0.5% participation bonus (in some cases, that may require an electronic billing system add-on that adds the necessary PQRS codes to claims). If not, you could be leaving an estimated $800 in reporting incentives per hospitalist on the table. Once the PQRS penalty phase begins in 2015, your group could lose 1.5% of CMS reimbursements. Eventually, failure to engage will spur an additional 1% penalty through the Value-Based Payment Modifier (VBPM).
Respond
SHM’s early feedback to CMS was based in part on a problematic Quality and Resource Use Report (QRUR) brought to the society’s attention by a member hospitalist. Dr. Torcson says SHM carefully reviewed that report to register its concerns about proper attribution, fair comparisons, relevant metrics, and other issues. In turn, CMS signaled its appreciation of SHM’s due diligence and has indicated a willingness to work with SHM to address its concerns. The lesson is that a constructive, collaborative process was eased by the willingness of an SHM member to help the society develop a thoughtful and thorough response—one that is more likely to yield sought-after changes by federal officials. “CMS reacts much better to physician groups that are willing to collaborate with them versus the ones that just want to deny, deny, deny that changes are coming,” Dr. Whitcomb says.
Communicate
CMS has indicated that lack of communication among individual physicians and groups won’t excuse anyone from the PQRS and VBPM programs. Hospitalists clearly have an advantage here, and experts say a continued focus on collaborative teamwork and making sure providers are on the same page could help ensure that everyone is making the necessary improvements in care. To keep the conversation going, initiate and take part in online discussions with fellow HM providers via the advocacy and public policy community of SHM’s Hospital Medical Exchange.
Plan
Which PQRS measures are most applicable to you and your colleagues? Make sure you review the final rules and develop a plan for how to address the performance measures that you can control, either directly or indirectly. For group practices with 100 or more eligible providers, the first performance year for the VBPM program begins Jan. 1.