The Centers for Medicare and Medicaid Services (CMS) released the 2010 Medicare Physician Fee Schedule Proposed Rule, which includes details on the 2010 Physician Quality Reporting Initiative (PQRI), on July 1, 2009, requesting comments. There were several changes compared to the 2009 PQRI program, such as the use of electronic health records (EHR) to report some measures, the possibility for group practices (with 200 eligible professional or more) to report measures as an entity, and the fact that in future years only NQF-endorsed measures will be considered by CMS to be added to the program. View the 2010 PQRI Highlights »

On August 27, the Heart Rhythm Society submitted a comment letter to CMS regarding the 2010 PQRI. The Society's comments addressed four topics: value of registries, timeline for transitioning from claims-based reporting, scope of quality reporting for EPs and the deficiencies in the PQRI program. Read the full Society comment letter (PDF, 220K).

Summary of the Society’s Comments:

Value of Registries
The Society is very supportive of registry reporting and emphasizes that the ICD Registry™ should be a recognized registry for PQRI reporting. While the ICD Registry is hospital-based, the Society would like to work with CMS to determine how this registry can be adapted to the PQRI system or recognized as an alternative opportunity for physicians to receive a bonus payment for participation and reporting, in addition to the hospital.

Timeline for Transitioning from Claims-Based Reporting
In the proposed rule, CMS is looking to move away from claims-based reporting as early as 2011. The Heart Rhythm Society is concerned that the timeline is too ambitious. While the Society supports registry reporting, CMS needs to ensure that all physicians have opportunities available for participating in a quality reporting system. For example, physicians are reporting into the ICD Registry, which is not PQRI certified, therefore it cannot be used to report data into the PQRI system. Furthermore, there are no registries for many EP procedures.

Scope of Quality Reporting for EPs
While many EPs can report on PQRI measures, most of these measures are geared toward primary care physicians and general cardiologists. Before reimbursing physicians based on their quality outcomes, CMS must ensure that appropriate outcomes measures are developed for specialists.

Deficiency in the PQRI program
The PQRI, or any alternative quality reporting system, especially a system that involves public reporting, and reimburses physicians based on this reporting, must include appropriate safeguards. Among others, the Society asked CMS to address the following issues:

• Provide interim feedback report to physicians.
• Display a disclaimer on the public PQRI page saying that some physicians may not participate in the PQRI program.
• Public Reporting — before any information is released to the public, the Society requests that a formal independent evaluation of the program’s processes and an analysis and validation of the data be conducted.
• Due process protections — As the Society has requested in the past, a timely appeal process should be developed for the PQRI and all quality reporting systems where physicians and other providers will be held accountable for quality reporting and patient outcomes.
• Cost impact — the Society recommends that CMS evaluate FDA final rule “Charging for Investigational Drugs under an Investigational New Drug Application” and adopt a similar process to require certified accounting records from vendors participating in PQRI in order to assess cost to physicians and other stakeholders.

On August 31, the Heart Rhythm Society submitted a separate letter to CMS commenting on issues with the reimbursement section of the proposed rule. In the Society’s comments, concerns were raised regarding CMS’ proposals to use the American Medical Association (AMA) Physician Practice Information Survey (PPIS) data to calculate practice expense inputs, eliminate consultation codes, remove physician-administered drugs from the sustainable growth rate formula, increase the current equipment usage rate from 50 to 90 percent, and shift several high-risk invasive cardiac arrhythmia procedures to minor or no risk category. Learn more »