ACP noted that CMS made a series of modifications that resulted in a dramatic reduction in both the number of relevant measures and the administrative burden associated with submitting data. ACP termed these revisions in the PVRP as being "critically important" and "essential" for the success of the quality improvement program.
Last fall, CMS advanced the PVRP with 36 measures – 22 of which were applicable to internal medicine specialists and subspecialists. ACP contended that because each of the CMS measures had a minimum of three potential G-codes, physicians and their staff would need to be familiar with as many as 39 potential codes for the 12-13 measures that might need to be reported for a 70-year-old woman with diabetes, coronary artery diseases and osteoporosis – a constellation of conditions that is not terribly uncommon in many practices.
ACP also recommended that CMS consider the use of CPT II codes when available, because commercial payers do not typically accept G-codes (G codes are Medicare-specific codes that are typically used by the program for reporting services under conditions that are unique or particular to the Medicare program, and therefore are generally not recognized by other payers). Physicians will be forced to report differently on the same measures for commercial payers if G-codes are the only option.
Over the past several months, ACP has had continued and positive discussions with CMS on how to improve the PRVP. Consistent with ACP's recommendations and its subsequent discussions with CMS, on Dec. 27, 2005, CMS revised its strategy and announced the decision to adopt a smaller core starter set of PVRP measures. CMS has identified 16 starter set measures out of the original 36 – seven of which are applicable to internists. Six of the seven measures were endorsed by the Ambulatory Care Quality Alliance (AQA). ACP consistently asserted the importance of AQA approval as a criterion for the set of measures:
CMS intends to provide confidential reports to program participants on how their care measures up to the prioritized starter set of measures. By participating in the program, interested physicians will be able to "test the waters" and gain experience in quality measurement and reporting before such reporting becomes tied to Medicare payments. ACP anticipates working with CMS to help design the reports, which may then be used for ongoing quality improvement efforts and potentially for maintenance of board certification through self-evaluation of practice performance for the American Board of Internal Medicine.
"The revisions announced by CMS are critically important ones" said ACP President C. Anderson Hedberg, MD, FACP. "As reporting and pay-for-performance (P4P) programs become more widespread, uniformity and a realistic set of measures that don't create huge administrative reporting burdens are essential for physician acceptance and the success of any quality improvement and measurement program."
"While the CMS program is voluntary, our members need to know that the program likely will become the prototype for a P4P program with financial incentives attached as early as later this year," Dr. Hedberg continued. "It's in the interest of all ACP members to understand the program and to consider participating in order to give them a 'leg up' when reimbursement is associated with it."
ACP continues to press CMS to implement additional payment for reporting data as part of the PVRP during 2006. Additional clarification is expected soon from CMS on several issues, including using CPT II codes.
The American College of Physicians is the largest medical specialty organization and the second-largest physician group in the United States. ACP members include 119,000 internal medicine physicians (internists), related subspecialists, and medical students. Internists specialize in the prevention, detection and treatment of illness in adults.
Last reviewed: By John M. Grohol, Psy.D. on 21 Feb 2009
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