PQRS Penalties Have Doubled for 2018 – Notices Have Been Mailed – You Have Until Dec 1 to Appeal
The CMS recently mailed notices to practices who failed to comply with PQRS requirements in 2016. Failure to comply with PQRS in 2016 will result in penalties applied in 2018.
Penalties have doubled (Medicare will take back as much as 6%). This topic deserves your attention.
Below are instructions on how to identify your status, then audit your performance (if you failed to comply), and then appeal (if you think you did in fact comply with PQRS in 2016).
Looking ahead:
Compared to what’s coming in 2019, PQRS is “child’s play”
and penalties will skyrocket
MIPS/MACRA, 2019’s reporting requirements have been described as “PQRS on steroids.”
- If you failed to comply with PQRS in 2016, the more complex rules in 2019 will likely be painful
- If you chose not to submit PQRS in 2016, you’re behind the learning curve. In 2019, you don’t have a choice
- If you complied with PQRS in 2016, but hated the 5-10 minutes of extra work, plan on doubling/tripling that amount of time in 2019
To some, the following is a shocking, controversial statement. To us, it’s common-sense advice:
Your job is not to comply with PQRS, MIPS, MACRA or other healthcare reform requirements.
Your job is to restore your patients’ functional deficits
Look at It This Way
Medicare is not judging you with an army of employees. Medicare is judging and punishing you with a supercomputer.
The way to thrive (spend your time treating and increase reimbursements) amidst healthcare reform is to use your own supercomputer to submit perfect coding and defense, while you are hands-on treating the patient.
Real-World Examples:
- Last year we learned that 98.2% of therapists using Systems4PT complied with 2015 PQRS requirements
- Only 1.8% did not comply – BY FAR the highest compliance in outpatient rehab
- So far, this year 100% have complied with 2016 PQRS requirements
- Our practices’ 2015 average revenue per claim was higher than 2014
- And our practices’ average 2016 revenue per claim was higher than 2015
- And by the way, their evaluation documentation time was half that of yours
If You’re Penalized for 2016 PQRS, We Recommend:
- Blame your low-tech, no-tech EMR
- Take 2019’s increased reporting requirements seriously
- Realize that “In 2019, penalties will be 3-4 times higher than today. I can’t afford to fail again”
- And take a look at Systems 4PT:
The undisputed highest compliance in the industry
The only EMR with increasing reimbursements
Documentation that takes half the time (click to watch the video)
That costs 1/3 less than you’re paying today
Treat More, Type Less TM
PQRS FOLLOW UP
Identify Your Status:
- Alert your staff to “be on the lookout” for any CMS documents that come in the mail. Don’t let the PQRS notice sit in a pile of mail
- If you don’t want to wait on snail mail, you can check your 2016 PQRS feedback report online in the Annual Quality and Use Reports website
- https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/AnalysisAndPayment.html
What to Do if You Failed the 2016 PQRS Requirements:
- Ask your EMR for an analysis of your PQRS participation in 2016
- This analysis should detail all activity in 2016:
- By therapist
- By Medicare patient
- By PQRS topic
- Analyzing this information will clarify your 2016 PQRS compliance, by therapist
- This analysis should detail all activity in 2016:
If You Want to Appeal the 2016 PQRS Penalty:
If you can prove PQRS with your data analysis, you should appeal. You must initiate this process before December 1, 2017. After that, you don’t have the option to appeal.
You can read instructions on the appeal process at this website:
