Are Your Therapists Ready for the 2015 PQRS Changes?

As mentioned last month, significant changes are on the horizon for therapists who have been participating in the PQRS program. (See “Final 2015 Physician Fee Schedule Rule Includes Changes for Therapy Providers”; 11/7/14.)  It’s not all bad news, but therapists will definitely see an increase in the amount of reporting and documentation required if they want to avoid negative payment adjustments down the road.

First, there will no longer be an incentive payment for successfully participating in the PQRS program.   In 2014, therapists could report nine measures (or as many measures applied) to qualify for the bonus payment OR they could choose to just report three measures to avoid a negative payment adjustment in 2016.  However, in 2015, the rules are changing.  The number of individual measures required to be reported in 2015 in order to avoid a 2.0% penalty in 2017 will increase from three to as many as nine, depending on the discipline and whether the provider is reporting via claims or registry.  Providers will still be required to successfully report on at least 50% of eligible Medicare patients for whom the measures apply.

For PTs reporting via claims, there are not nine measures available to report.  Therefore, PTs reporting via claims must report all six measures available for claims-based reporting which include Measures 128, 130, 131, 154, 155, and 182.

For OTs reporting via claims, there are nine available measures, all of which must be reported: Measures 128, 130, 131, 134, 154, 155, 181, 182, and 226.

For PTs reporting via registry, there are not nine measures available to report (unless the therapists are using FOTO).  Therefore, PTs reporting via registry must report all eight measures available for registry reporting which include Measures 126, 127, 128, 130, 131, 154, 155, and 182.  Additional measures are available for those therapists using FOTO including Measures 217, 218, 219, 220, 221, 222, and 223.

For OTs reporting via registry, there are more than nine available measures from which OTs can choose, but only nine must be reported.  The available measures include 126, 127, 128, 130, 131, 134, 154, 155, 173, 181, 182, 226, and 402.

Providers must report at least one cross-cutting measure.  This shouldn’t be a problem for therapists, though, as Measures 128, 130, 131, 134, 182, and 226 have all been designated as cross-cutting measures.  Another change is that the Back Pain Measures Group has been removed for 2015.

I mentioned earlier that there was a bit of good news.  For starters, CPT codes 97110 and 97140 have been removed from the list of codes which require reporting for Measure 130 (Documentation of Current Medications in the Medical Record).  Also, CMS has delayed bringing nonphysician eligible professionals into the Value-Based Payment (VM) Modifier program until 2018.  That means that therapists will not be subjected to the additional VM penalty in 2017 based on their 2015 PQRS performance.  However, if they haven’t already, therapists should get acclimated to the PQRS program soon since failure to participate (or reporting unsuccessfully) in 2016 will result not only in a 2018 2.0% negative payment adjustment for PQRS but also a 4.0% penalty under the VM program.

Going forward, it will be imperative for your therapy providers to understand the particulars of PQRS reporting including which measures to report and when they can be reported.  The alternative is to face reduced payments in the future.