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Physician Quality Reporting System

Resources to help you avoid the 2017 PQRS penalty by successfully reporting in 2015.

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2015 PQRS Facts:

  • If you are a Medicare Part B enrolled physician, there are no exemptions for the PQRS penalty.
  • Individual reporting is captured by the physician’s National Provider Identifier (NPI).
  • Electronic health records are not required to report PQRS.
  • IRIS™ Registry will help automate PQRS reporting.

PQRS Changes for 2015

To avoid the 2 percent 2017 penalty of all Medicare Part B, Medicare as a secondary payer, and Railroad Medicare allowables less durable medical equipment and injected drugs, ophthalmologists must successfully report one of the six reporting options (see Reporting Options section below).

The following changes are in effect for 2015 PQRS reporting:

  • Four new measures have been added to registry reporting:

  • Two new measures are only available to report through an EHR:


  • The cataracts measures group increased to 8 measures, including the newly added Measures 388 and 389.

  • The claims and qualified registry reporting options increased to 9 measures to avoid the penalty, and include the requirement that at least one “cross-cutting” measure must be reported.

View all 2015 PQRS Measure Specifications


2015 Reporting Options

Option 1: IRIS™ (Intelligent Research in Sight) Registry EHR System Integration

Academy members with EHR can have the Academy's IRIS Registry integrate with their EHR system to extract data needed to report clinical quality measures for PQRS which can also meet the CQM requirements for 2015 EHR Meaningful Use Incentive Program, as well as Stage 2 Menu Measure 6 (specialized registry). 

Report nine clinical quality measures across three quality domains. If your EHR does not contain patient data for nine measures covering three domains, then report all of the measures for which there is Medicare Part B patient data. Physicians are required to report on at least one measure for which there is Medicare Part B data.

Pros Cons
  • No manual data entry
  • Simultaneously reports for both EHR MU and PQRS
  • High success rate
  •  Requires EHR certified to the 2014 standards be in place for the full year.

Deadlines: 

  • March 1, 2015 submit signed IRIS Registry agreements to report Stage 2 Meaningful Use Menu Measure 6.
  • June 1, 2015 submit signed IRIS Registry agreements for EHR Integration for 2015 PQRS.
  • Dec. 1, 2015 submit signed consent allowing data to be sent to CMS.

Option 2: Direct EHR Product

Some EHRs will report directly from EHR to CMS to meet the requirements of PQRS, as well as the CQM requirements for the EHR Meaningful Use Incentive Program. Report nine clinical quality measures across three domains. If your EHR does not contain patient data for nine measures covering three domains, then report all of the measures for which there is Medicare Part B patient data. Physicians are required to report on at least one measure for which there is Medicare Part B data.

Option 3: Cataracts Measures Group

Cataract surgeons can report the Cataracts Measures Group through the IRIS Registry.

New in 2015: This measures group has eight measures. 

Twenty surgical cases must be reported. Of the twenty, at least eleven patients must have Medicare Part B insurance. The remaining patients may have Medicare Advantage or commercial insurance.

View all 2015 PQRS Measure Specifications

Pros Cons
  • Low burden option for physicians without EHR.
  • High success rate in avoiding PQRS penalty
  • Not an option for non-cataract surgeons
  • Not an option for attesting for meaningful use

Deadlines:

  • By Aug. 1, 2015 submit signed IRIS Registry agreements.
  • By Sept. 30, 2015 provide pre-surgical forms and perform at least 20 cataract surgeries
  • By Dec. 1, 2015 submit signed consent, allowing data to be sent to CMS
  • By Jan. 15, 2016 submit all data to IRIS Registry.

Option 4: Individual Measure Reporting via IRIS Registry Web Portal (No EHR)

Physicians without an EHR can use the IRIS Registry to report individual measures.

Option A: Identify nine measures across three quality domains for at least 50 percent of the qualifying Medicare Part B, Medicare as a secondary payer, and Railroad Medicare patients seen between Jan. 1 and Dec. 31, 2015.  At least one measure must be a “cross-cutting” measure. When you use the Web portal to select a measure, you will be provided with a measure description that indicates what type of measure it is.

If you report less than nine measures, CMS will use the Measure Application Validity (MAV) process to determine whether you should have reported additional measures.

Option B: Identify nine measures across three quality domains for at least 50 percent of total patients seen between Jan. 1 and Dec. 31, 2015. Two measures must be “outcomes” measures, and if two outcomes measures are not available, must report at least one outcomes measure, and one of the following types of measures: resource use, patient experience of care, efficiency / appropriate use, or patient safety. When you use the Web portal to select a measure, you will be provided with a measure description that indicates what type of measure it is.

Pros Cons
  • Measures do not have to be entered in real time.
  • Option B, can report new ophthalmology measures being developed by IRIS Registry not available in PQRS measure set
  •  More labor intensive than EHR Integration or Cataracts Measures Group.

Option 5: Claims Based Reporting From Your Office

Physicians who have been successfully reporting PQRS from the office setting may choose to continue to do so. To avoid the penalty, nine clinical quality measures across three domains, including at least one “cross-cutting” measure, should be submitted for at least 50 percent of the Medicare Part B FFS patients seen during the reporting period.

However in 2015 there are only eight measures that apply to most ophthalmologist that can be reported via claims due to the deletion of claims reporting option for Measure 18 Diabetic retinopathy: documentation of presence or absence of macular edema and level of severity of retinopathy. Physicians reporting fewer than nine measures across three domains will be subject to the MAV process.

Pros Cons
  • Familiarity
  •  There are not nine ophthalmic measures that can be reported via claims.
  • All physicians will be subject to the MAV process and may not successfully avoid the penalty.
  • This option will likely be eliminated in future PQRS years

Option 6: Group Reporting Option

Ophthalmologists who are part of a large multi-specialty group practice may choose to report every physician in the group reporting option. Details can be found at www.cms.gov.


Frequently Asked Questions

Question Answer

What are the six quality domains?

PQRS measures are grouped into six quality domains:

  • 1. Patient  safety
  • 2. Person and caregiver-centered experience and outcomes
  • 3. Communication and care coordination
  • 4. Effective clinical care
  • 5. Community / population health
  • 6. Efficiency and cost reduction
What are "cross-cutting measures"? These are primary care measures that are intended to represent core competencies that apply to multiple specialties. 

I noticed that the Cataracts Measures Group only has 8 measures. Will we need to add another measure for reporting in 2015 in order to meet the requirement for 9 measures?

Successfully reporting the Cataracts Measures Group is sufficient to avoid the penalty. You do not need to add a 9th measure.

We have an ophthalmologist and an optometrist in our practice and have been considering the Cataracts Measures Group. Is the optometrist able to submit any of these group measures? 

Only cataract surgeons can report the Cataracts Measures Group. Optometrists should select another method to successfully report.

Is it possible to submit some measures by IRIS registry and some by claims in order to get to a total of nine? 

Unfortunately not. Successful reporting is accomplished via claims, registry, or EHR reporting, but not via a combination of more than one method.

If a patient has cataract surgery bilaterally during the reporting period of 2015, can both surgeries be reported separately and count as two for the Cataracts Measures Group?

If the surgeries are performed on different days, they can both be included. However, separate surveys will need to be submitted for each.

Does IRIS send out the survey/questionnaires for patient satisfaction and visual improvement measures for the Cataracts Measures Group? 

Are these two different questionnaires?

What if the patients don’t respond?

IRIS has the surveys available in the registry. They are barcoded with the patient information. IRIS will mail the practice pre-paid envelopes to be handed to the patient. 

There are a total of three survey : preop VF-8R, postop VF-8R, and a postop Surgical Care Survey. As long as you have administered the surveys, you’ll get credit for measures 303 and 304.

Select patients according to the measure specifications. They do not have to be consecutive.  

Once selected, the practice will manually enter in data for the measures not requiring surveys. Patients who have not returned their surveys will be contacted by IRIS.

Since Measure 18 can only be reported via EHR, can we report it by EHR and submit the other eight via a registry?

Only one method of reporting will qualify, not a combination of two.

When entering patient demographics into IRIS Registry, all of our selected measures show up. 

Do I need to enter in data even on those measures that are not applicable?

According to IRIS Registry staff, you can leave the non-applicable measures blank and report only on those measures that apply.

Measure 317 pertaining to blood pressure is not suggested on the AAOE site. Is this a measure ophthalmologists should be reporting?

The issue with measure 317 is that the ophthalmologist would have to document a follow- up plan if the patient has a high BP reading. The Academy feels the ophthalmologist is not responsible for the plan of action and ensuring the control of BP. However, if it fits your practice, you may go ahead and report the measure.

The Cataracts Measures Group requires two cross-cutting measures be reported, (i.e., measures 130 Documentation of medication and 226 Smoking cessation).  Are we to report on only the 20 cataract patients or do we need to report on all our Medicare Part B patients?

You only need to report on your 20 surgical patients.

Pertaining to the Cataracts Measures Group: What if the 20 patients chosen do not have any complications pertaining to Measures 192, 388 and 389? Will we need to report additional measures?

The measures will still count even without complications. Review each measure for the appropriate modifier or code to submit.

If we were to add a new physician to our practice in August or September of 2015, how would s/he t meet the requirements?

Start reporting PQRS the day the new physician begins practice in your office.

We notice that measure 1 Diabetes HbA1c poor control is not listed as one of the cross-cutting measures. Is this measure not available via claims reporting for ophthalmologists?

Ophthalmologists aren't really responsible for this quality action; however, it’s good if they ask about HbA1c levels and reinforce strict control for overall health as well as ophthalmological complications. Since ophthalmologists are neither responsible for maintaining good control of HgA1c nor personally check the level of HgA1c, it is not a recommended measure.

I am unclear on the Medicare Part B patients for PQRS submission. What if we do not have patients with this type of insurance?

PQRS applies to Medicare Part B, Medicare as a Secondary Payer, and Railroad Medicare patients. Depending on your contract with Medicare Advantage Plans, it could include those patients as well.

Why does AAOE include measures referring to cutaneous melanoma (137, 228, and 224)? These do not pertain to choroidal melanoma.

We have included these measures since Oculofacial surgeons can see and treat these patients, or refer for treatment. These measures are the only ones available to this subspecialty.

What if practices try to participate in PQRS, but fail to do it successfully; is failure to participate successfully the same as failure to participate at all?

Does this result in the 2% cut for VBM as well as 2% cut of PQRS?

Unfortunately, unsuccessful reporting will result in the same penalty as non-reporting. You may also be subject to the Measure applicability validation (MAV) audit.

Yes.

We have not been reporting on patients with Medicare as a Secondary Payer. Should we be?

Yes.  Medicare as a Secondary Payer is part of the PQRS program/penalty.

Pertaining to the Cataracts Measures Group, I noticed that two of the measures do not include complex cataract. Does this mean that CPT 66982 cannot be included as one of the 20 patients?

These are more complex patients who are more likely to have worse outcomes, which is why CPT 66982 has been excluded from these measures. Therefore, it should be avoided for reporting the Cataracts Measures Group.

We listened to the PQRS 2015 webinar, but still have a question regarding our multi-subspecialty Ophthalmology group: Do all of our physicians need to report the same measures or can some choose the Cataracts Measures Group, while others choose measures that are more applicable?

PQRS reporting is not based on the group unless you are submitting via GPRO. It is based on each individual NPI number so they can participate using different measures. 


 

Disclaimer and Limitation of Liability

All information provided by the American Academy of Ophthalmology, its employees, agents, or representatives who participate in the Academy’s coding service is based on information deemed to be as current and reliable as reasonably possible. The Academy does not provide legal or accounting services or advice, and you should seek legal and/ or accounting advice if appropriate to your situation. Coding is a complicated process involving continually changing rules and the application of judgment to factual situations. The Academy does not guarantee or warrant that either public or private payers will agree with the Academy’s information or recommendations. The Academy shall not be liable to you or any other party to any extent whatsoever for errors in, or omissions from any such information provided by the Academy, its employees, agents or representatives. The Academy’s sole liability for any claim connected to its provision of coding information or services shall be limited to the amount paid by you to the Academy for the information or coding service.

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