Penalties & Bonuses: PQRS for Mental Health
What is the PQRS? The Physicians’ Quality Reporting System (PQRS) was established as part of the Tax Relief and Health Care Act of 2006 (TRHCA). It started as a voluntary reporting program that provides a financial incentive for certain health care professionals, including psychologists, who participate in Medicare to submit data on specified quality measures to the Centers for Medicare and Medicaid Services (CMS). The recently-passed Patient Protection and Affordable Care Act of 2013 (PPACA), also known as “Obamacare”, will require mandatory PQRS reporting in 2015 (and into the future) and also changes the name from PQRI to the Physician Quality Reporting System (PQRS).
This means that mental health professionals who are enrolled in Medicare under the clinical psychologist designation, have an NPI number and are enrolled in the PECOS program must begin reporting certain quality measures to CMS starting in 2013 or they will start to be penalized in 2015. (Failure to enroll in the PECOS program results in a denial of Medicare claims as of 2011, so if you’re participating in Medicare, you’re most likely already enrolled in PECOS). However, to help avoid penalties, CMS is helping facilitate enrollment: psychologists participating in the program for the first time will only need to report one service measure for at least 1 applicable client in 2013 to avoid 2015 penalties. There are bonus payments available for participation, but they require more than this minimum reporting.
Bonus payments can be earned through 2014 just for reporting, regardless of treatment outcomes: providers who successfully report on 50% of the applicable cases for a given measure will be eligible for a bonus of 0.5% of their total allowed Medicare charges for the 2013 reporting period. That’s an extra 5% on all claims received from Medicare, not just the ones reported on! The 5% bonus payment is for 2013 and 2014, and CMS will also provide confidential feedback reports for these professionals. However, successful reporting means that measures reported on are appropriate for the client and services provided; for example, if the measure involves adult major depressive disorder, it may not be used for clients under 18. And, in order to report on 50% of applicable cases in 2013, don’t delay: if you’re planning on earning the bonus, start now!
Starting in 2015, the incentive bonuses will cease, and penalties will be imposed on those who do not successfully report PQRS measures. Because Medicare requires time to analyze the data submitted, the 1.5% penalty will be levied in 2015 for 2013 data, and the 2% penalty will be levied in 2016 for 2014 data. Penalties will apply to all Medicare charges by a provider.