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EHR and practice management for mental / behavioral health

Are you going to be penalized on all of your Medicare reimbursements?

PIMSY behavioral health software penalties!

by Leigh-Ann Renz, 1/2/15

Mandatory PQRS Reporting for Mental / Behavioral Health

Happy New Year! With the festivities behind us, it's time to turn our attention to making sure you're 2015 compliant, which includes PQRS reporting for 2014. If you see clients who are Medicare Part B or Railroad, you must report for PQRS - and yes, this does apply to mental / behavioral health and substance abuse.

This means that you must report on applicable measures, or your Medicare reimbursements may be docked. A 1.5% penalty will be levied in 2015 for 2013 data, and a 2% penalty will be levied in 2016 for 2014 data. Click here for all the details.

There are several methods for PQRS reporting, the simplest and cheapest one being claims-based. For claims-based reporting, you must attach a g-code on the claim for at least 50% of the visits / sessions that qualified for dates of service 1/1/14 - 12/31/14. The deadline to file these claims is 2/28/15.

How can you make sure you've met the 50% rule and/or otherwise confirm your PQRS submissions?  

If you have previously registered on the IACS site, your registered PQRS Representative can log in and see on a PQRS dashboard how you have done year-to-date. You would have to compare that number to your internal documentation on the number of Medicare claims that you have filed through the same time period. If you have not signed up to be on IACS, it is a two-step process:

Two separate individuals would need to register for IACS accounts. The first individual would register as a Security Official: this individual does not have access to the PQRS Dashboard / Feedback Reports and is only an administrative role to approve new users and user changes. They will then receive an email requesting a IRS document to verify the organization and approve their account.

Once the Security Official has been registered and approved the second individual can register as the PQRS Representative: this is the role that can access the PQRS Dashboard / Feedback Reports. Once the PQRS Representative has registered online, the Security Official would then approve their account. The PQRS Representative would then receive an email with their User ID and temporary password so they can create a new password. The PQRS Representative will then be able to access the PQRS Dashboard / Feedback Reports at www.qualitynet.org/pqrs.

IACS Account - Security Official Registration Instructions:

1. Navigate to www.qualitynet.org/pqrs
2. Select: Register (Underneath Sign to your Portal)
3. Select: Physician Quality Reporting System/eRx (Located 5 up from the bottom on the left hand side.
4. After accepting the Terms, enter the appropriate information in the New User Registration screen.
5. Enter the verification code sent to your registered email.
6. Enter the appropriate information under the Professional Contact Information section
7. Select the appropriate role (Security Official) under Access Request. Note: The SO will need to indicate their 2-factor requirement. (Yes = Organizations that are submitting EHR, No = all other organizations)
8. Enter appropriate information to create organization.
9. Enter the justification information and select Next.
10. Complete the Authentication Questions. Note: Fields are case sensitive.
11. Verify that the information is correct on the Review Registration Details screen and select Submit.
12. Capture the request number on the Registration Acknowledgement screen.
13. Once the request is approved, the user will receive a User ID and temporary password in two separate emails to the registered email address.
14. The user can log in to change the password and view his/her profile that displays the appropriate Security Official role. To complete this step, navigate to https://applications.cms.hhs.gov.
15. Select: Enter CMS Application Portal
16. Select: Account Management
17. Select My Profile.

Once this account is approved, the individual that will have the PQRS Representative Role will register for their account.

PQRS Representative Registration Instructions:

1. Navigate to www.qualitynet.org/pqrs
2. Select: Register (Underneath Sign to your Portal)
3. Select: Physician Quality Reporting System/eRx
4. After accepting the Terms, enter the appropriate information in the New User Registration screen.
5. Enter the verification code sent to your registered email.
6. Enter the appropriate information under the Professional Contact Information section.
7. Select the appropriate role (PQRS Representative)
8. Enter search information to associate with the desired organization.
9. Once the search is complete, select the appropriate organization from the drop down box to associate.
10. Enter the justification information (ie: PQRS Representative for this organization).
11. Select: Next
12. Complete the Authentication Questions. Note: Fields are case sensitive.
13. Verify that the information is correct on the Review Registration Details screen and select Submit.
14. Capture the request number on the Registration Acknowledgement screen.
15. The End User request is routed to the SO or BSO for approval. Once the request is approved, the user will receive a User ID and temporary password in two separate emails to the registered email address.
16. The user can log in to change the password and view his/her profile that displays the appropriate PQRS Representative role. To complete this step, navigate to https://applications.cms.hhs.gov .
17. Select: Enter CMS Application Portal
18. Select: Account Management
19. Select My Profile.
20. This will allow the PQRS Representative entry into the PQRI Portal, located at: www.qualitynet.org/PQRI for access to feedback reports / PQRS Dashboard.

Acceptable IRS docs consist of the following:
• CP 575 – Letter received from the IRS granting the Employer Identification Number
• Letter 147C – Verification of Employer Identification Number
• Form 9787 – Electronic Federal Tax Payment System
• CP 225 - Payment applied to tax payer account
• Letter 2645C - Status letter for installment agreement
• CP 210 – Statement of adjustment
• CP 267 – Overpayment notice – response required
• CP 403 – Request for information about Form 5500 or 5500-EZ
• CP 2100A – Check Backup withholding list
• CP 504 – Pre-addressed coupons
• Letter 387C – Recertification for tax period
• Letter 2782C – Federal tax deposit penalty

Mailing Address:
QualityNet Helpdesk
1401 50th Street, Suite 200
West Des Moines, IA 50266

What if I don't meet the 50% requirement or don't want to do claims-based reporting?

If you haven’t been reporting via claims throughout the year, you may not have enough un-billed claims to capture 50% of your qualifying clients. Claims cannot be rebilled or otherwise re-processed for PQRS, and if you haven’t been reporting throughout the year, you may not be able to avoid the penalty via the claims-based method. In that case, you’ll have to report via registry in order to avoid the penalty.

The downsides to using a registry are that most charge a fee, and you have to file / submit your data to an outside vendor, which of course is more work than simply processing it in your EHR. The upside is that you may still qualify for the incentive, as you are reporting on the whole year. Registries may have an earlier deadline date than 2/28/15, so be sure to confirm this with them. Click here for a complete list.

There are also other reporting options such as GPRO or qualified clinical data registry. Click here for details.


Leigh-Ann Renz is the Marketing & Business Development Director of PIMSY EHR. For more information about electronic solutions for your practice, check out Mental Health Practice Management

Resources - PQRS

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