2011 MPFS— Society’s Comments on Quality Related Provisions

The Heart Rhythm Society has commented on the 2011 Physician Fee Schedule proposed rule released on June 25, 2010 by the Centers for Medicare & Medicaid Services (CMS), which updates Medicare payment policies for the year 2011. Among the issues addressed in that comment letter are the elimination of the consultation codes, the rebasing of the Medicare Economic Index, Remote Cardiac Monitoring Services.

Because there are many initiatives that represent the implementation of the Patient Affordable Care Act (PACA) and the shift to physician payment that is tied to quality outcomes, the Society submitted a separate comment letter on August 24 focusing exclusively on the Physician Quality Reporting Initiative (PQRI) and related quality reporting initiatives. Read the Society's comment letter outlining our recommendations on the proposed quality reporting changes (PDF, 300K).

PQRI
One important program that is modified in the proposed rule is the PQRI. As part of the modifications to PQRI, CMS proposes to implement several provisions of PPACA that changed the structure and function of the PQRI program. (Learn more about the quality related provisions.) The Heart Rhythm Society commends CMS for making improvements to the PQRI program and notes that there are many elements we support. However, we will continue to work with Congress and the Administration to delay any penalties until PQRI is more physician-friendly. We will also continue to educate Congress that physician reporting for quality should be a voluntary, non-punitive process, critical for wider implementation.

Specialty-Specific Clinical Quality Measures
There are currently only a limited number of performance measures that are optimal or even available to measure heart rhythm care. The Society believes that EPs should not be denied an incentive payment or be subject to a penalty (after 2015) if the available quality measures are not applicable to their specialty.

For these reasons, the Society recommends that CMS considers the inclusion of additional approved performance measures to the PQRI Program, including the development of an atrial fibrillation measure group.

Electronic Prescribing Incentive Payments
CMS also proposed to penalize eligible physicians who fail to participate in the 2011 electronic prescribing program and do not qualify for an exemption would be subject to financial penalties in 2012. The Society recommends CMS to delay the implementation of financial penalties for the e-prescribing program.

Alignment of PQRI and other CMS Quality Improvement Initiatives
To reduce burden and to avoid duplicative reporting, The Society recommends that CMS coordinate and align all provider-based and physician-level reporting, the meaningful use requirements, and electronic prescribing program requirements.