Medicare Quality Reporting Programs 2016

Overview: 

Physicians who participate in Medicare face a range of reporting obligations. Although not quite a "pay for performance" system at the present, in recent years Medicare has increased the number of reporting programs which track a variety of data. PQRS, Meaningful Use, and the Value-based Payment Modifier all tie physician compensation under the MPFS to reporting of data.

Reporting under these systems, however, is a complex and detailed process. Often there are multiple reporting mechanisms from which a physician may choose, each of which may require its own specific data set. Failure to properly report under these various mechanisms can result in significant reductions in overall MPFS compensation. Moreover, data reported today will form the basis for future compensation reductions. Where a payment reduction should have occurred, but did not due to improper reporting, any overpayment retained more than sixty days after it was identified or should have been identified will convert to false claims. The MIPS system will consolidate much of the reporting, but will eventually expose providers to even higher levels of upward or downward payment adjustment than they currently face. 

This presentation examines the three main physician reporting mechanisms that Medicare currently has (PQRS, Meaningful Use, and the Value-based Payment Modifier), providing brief background and discussing common problems for each system, as well as areas of overlap between them. The presentation also addresses MIPS, and how the current systems relate to it. In addition, the presentation explains the False Claims Act liability inherent in both the current systems and in MIPS, and how improper reporting under these systems can potentially result in overpayments. Finally, the presentation discusses proactive steps that physician practices can take to help ensure compliance with these systems to avoid such liability. 

Why should you Attend: 

Under the current systems, physicians face a range of upward and downward payment adjustments to all of their Medicare Physician Fee Schedule payments; under MIPS, this amount will eventually be a +/- 9% payment adjustment. These systems are complex and highly technical. Moreover, improper reporting can require repayment of money to Medicare, and may result in exposure under the Federal False Claims Act, which recently had its penalties nearly doubled. 

Areas Covered in the Session:

Physician Quality Reporting System (PQRS) compliance

"Meaningful Use" program compliance.

Value-based Payment Modifier compliance.

Merit-based Incentive Payment System (MIPS) compliance.

Potential False Claims Act exposure under these systems.

Who Will Benefit:

Physicians

Practice managers

Compliance officers

Speaker Profile :

Daniel F. Shay is an attorney with Alice G. Gosfield and Associates, P.C. His practice is restricted to health law and health care regulation focusing primarily on physician representation, fraud and abuse compliance, Medicare Part B reimbursement, and HIPAA compliance in the physician context. He also has a keen interest in intellectual property issues, including copyright, trademark, data control, and confidentiality. He has also focused his attention on provider control of commerce in data, electronic health records license agreements, physician advertising, enrollment in Medicare, quality reporting and quality measurement, physician use of non-physician practitioners, and physician use of social media. Mr. Shay received his Bachelor of Science degree cum laude in 2000 from Vanderbilt University and his juris doctorate degree from Emory University School of Law in 2003. 

Mr. Shay is admitted to the Pennsylvania Bar, is a member of the American Health Lawyers Association, and is the Vice Chair of Research and Website for the American Health Lawyers Association's Physicians and Physician Organization Practice Group.