Overview of Medicare’s Regulatory Programs Bob Jasak Deputy Director, Regulatory & Quality Affairs

1. Overview of Medicare’s Regulatory Programs Bob Jasak Deputy Director, Regulatory & Quality Affairs American College of Surgeons

2. Data Collection Pay-For-Reporting Public Reporting Pay-for-Performance/ Value-Based Purchasing

3. Overview

4. Overview

5. Physician Compare (Public Reporting) Value-Based Payment Modifier (Value-Based Purchasing/ Pay-for-Performance) PQRS (Pay-for-Reporting) Registries QCDRs (Qualified Clinical Data Registries) CLAIMS EHRs

6. Physician Compare (Public Reporting) • Group Practice Performance Rates on quality measures (2014 target) • Patient Experience of Care Data: (2014 target) • Specialty Society Specific Data • Individual performance data (target 2015)

7. Physician Compare (Public Reporting) Value-Based Payment Modifier (Value-Based Purchasing/ Pay-for-Performance)

8. Value-Based Payment Modifier (Value-Based Purchasing/ Pay-for-Performance) • Bonuses: • Beginning in 2015 • Budget neutral program (amounts of bonuses unknown until penalties determined) • Penalties: • 2015: -2% for non-PQRS participants (combined VBPM and PQRS penalty) • 2015: up to -1% even if PQRS compliant • 2016: -4% for non-PQRS participants • 2016: up to -2 percent even if PQRS compliant

9. Physician Compare (Public Reporting) Value-Based Payment Modifier (Value-Based Purchasing/ Pay-for-Performance) PQRS (Pay-for-Reporting)

10. Incentives Bonuses Expiring Separate Penalties (increasing to 2%) Quality Measures Specific Menu of Measures Heavy favor toward NQF-endorsement Year long submission process Predominately Process Measures Limited Measures for some Specialties Low Participation All EPs: 32% General Surgery: 20% Vascular: 32.4% Colon/Rectal: 28.2% PQRS (Pay-for-Reporting) Increasing Requirements Elimination of “low bar” reporting mechanisms to avoid penalty Increasing from 3 to 9 individual measures

11. Additional Individual Measures of Note

12. Physician Compare (Public Reporting) Value-Based Payment Modifier (Value-Based Purchasing/ Pay-for-Performance) PQRS (Pay-for-Reporting) Registries QCDRs (Qualified Clinical Data Registries) CLAIMS EHRs

13. Future of Claims-Based Reporting: • Limited to mostly process measures • High administrative burden • 2014: CMS eliminated the claims-based reporting option for reporting Measures Groups • CMS has been explicit about desire to eliminate this as an option CLAIMS

14. Physician Compare (Public Reporting) Value-Based Payment Modifier (Value-Based Purchasing/ Pay-for-Performance) PQRS (Pay-for-Reporting) Registries QCDRs (Qualified Clinical Data Registries) EHRs CLAIMS

15. EHR Quality Measure Reporting • Lower administrative burden • Only 63 PQRS approved EHR reportable quality measures (2014) • None of the measures in the Perioperative or General Surgery Measures Groups is specified for EHR-based PQRS reporting • Pilot project to streamline PQRS EHR Reporting and EHR Meaningful Use Reporting- but without applicable measures there is nothing to streamline • ACS work with Epic EHRs

16. Physician Compare (Public Reporting) Value-Based Payment Modifier (Value-Based Purchasing/ Pay-for-Performance) PQRS (Pay-for-Reporting) Registries QCDRs (Qualified Clinical Data Registries) EHRs CLAIMS

17. ACS Surgeon Specific Registry • Approved for participation in PQRS beginning in 2012 • Online for 2013 Reporting • Also built on platform collecting information for ABS MOC and Caselog • Current Limitations on this point-of-entry: • Limited to collecting information on PQRS approved measures • Only available for an individualto report on Measures Groups (which only requires reporting the Measures Group across 20 patients (including 11 Medicare patients) • Not currently available for group practice reporting (unless each surgeon reports separately as an individual • Not available to report individual measuresoutside of a measure group (which in 2014 will require reporting a measure across 50% of patients who are eligible to be reported on for a given measure) Registries

18. Physician Compare (Public Reporting) Value-Based Payment Modifier (Value-Based Purchasing/ Pay-for-Performance) PQRS (Pay-for-Reporting) Registries QCDRs (Qualified Clinical Data Registries)

19. QCDR Quick Facts • Concept mandated by Congress (at ACS and others’ requests) in the “Fiscal Cliff Bill” to be implemented by January 1, 2015 • Theory was to provide a PQRS bypass for physicians participating in clinical registries that provide more value and quality improvement opportunities than the measures currently approved in PQRS. • ACS responded to early 2013 CMS request for comments and again in official proposed rule • CMS qualification criteria finalized in CY 2014 Physician Fee Schedule Final Rule (released by CMS on November 27, 2013) QCDRs (Qualified Clinical Data Registries)

20. QCDR Criteria • Only available for individual physician participation (no group practice reporting) and must be physician specific • Measure Sources: CG-CAHPS, NQF-endorsed measures, measures used by boards or specialty societies, and measures used in a quality collaborative • Report on at least 9 measures (across 3 National Quality Strategy domains) • Report on at least 50% of patients eligible for each measure selected • Report on at least 1 outcome measure (example: unplanned readmission) • At least quarterly feedback reports QCDRs (Qualified Clinical Data Registries)

21. Physician Compare (Public Reporting) Value-Based Payment Modifier (Value-Based Purchasing/ Pay-for-Performance) PQRS (Pay-for-Reporting) Registries QCDRs (Qualified Clinical Data Registries) CLAIMS EHRs