CLIENT REACTIONS TO PQRI

PQRI: Why I am not participating

Family Physician, Mt. Gilead, Ohio

I have elected not to participate in PQRI for several reasons, many of which pertain to the principles addressed in the American Academy of Family Physician’s Policy on Pay for Performance.

The financial “reward” is minimal. My CMS intermediary on form 1099-MISC listed my 2006 Medicare income as $33,250. (For the purposes of determining a PQRI payment, any laboratory payments included in this figure must be subtracted since PQRI covers only services paid under the Physician Fee Schedule.)

When the adjusted figure is multiplied by 1.5% and then by 50% (for the 6-month reporting period), I have the potential to earn a maximum of $250; probably less. If I perform only 3 measures on my 30 Medicare diabetes patients, I will be paid $2.77 per measure. Many physicians plan to do at least 4 or 5 measures to make sure they reach the 80% minimum needed on at least 3 measures, which drives down their effective payment rate even further. The reward is not sufficient to cover the additional administrative costs to participate in the program.

The effort is burdensome. Additional work will be needed to collect the data and submit it to CMS, whether a practice is still using paper charts or has updated to an electronic medical record (EMR). I have been using an EMR for more than 5 years, and even with its capabilities, additional steps would be needed to complete the reporting. Compared with small practices, larger practices may have the economy of scale to financially justify performing PQRI. PQRI simply is not designed to accommodate practices of all sizes and technological capabilities.

We’re penalized for non-synchronous submissions. Measure results must be submitted simultaneously with the office visit charges. “Look back” submissions are not permitted without a claims submission. If a data submission is missed, there is no opportunity to submit the information later unless you have the patient return for another charged office visit.

The analysis process is unsatisfactory. The data are not aggregated, analyzed, or reviewed by an independent third party. There is no corroboration of the information. This is important despite CMS’s reassurance that data on individual physicians or groups will not be released to the public.

There is no appeals process. If CMS denies a PQRI payment even when measure information is provided in an appropriate fashion, there is no recourse for an appeal. The program needs to provide an appeals process for the performance data results and payments.

Payments should be timely. CMS will not pay for the information doctors provide until mid-2008. This is not timely.

Data feedback is lacking. Physicians are unable to access the submitted information and peer comparisons in real-time. In fact, this function will not be available until at least mid-2008. This deficiency prevents PQRI from being a quality data informational resource.

Registries are ignored. Although the most efficient method for submitting data would be the use of a registry embedded within an EMR, CMS does not allow for registry submission. My EMR has this capability. Again, the program needs to minimize the administrative, financial, and technological barriers to participation.

Collected data are undervalued. Beyond the issue of payment to cover the cost of data collection is a consideration of the true value of the data being sought. CMS should recognize this inherent value and reimburse physicians appropriately.

RHCs and FQHCs do not qualify. PQRI covers only services paid under the Physician Fee Schedule. Thus, clinical lab services, Rural Health Clinics, and Federally Qualified Health Clinics are ineligible. Any laboratory payments, as mentioned in my first reason above, must be subtracted. I am part of an RHC.