Following a Centers for Medicare & Medicaid Services (CMS) announcement of a proposal to conduct audits of physicians and other eligible professionals who received incentive payments under the Medicare Physician Quality Reporting System (PQRS) and ePrescribing (eRx) programs, the AMA called on the agency to abandon its plans because of numerous implementation problems.
Adding the threat of retrospective audits to two already problematic programs will only deter physicians from participating in the programs, AMA Executive Vice President and CEO James L. Madara, MD, said in the letter (PDF).
The AMA outlined the many issues these programs have presented for physicians, including:
- Inadequate preparation and response time. CMS makes yearly changes to the PQRS program requirements but does not release updated measure specifications until close to the start of the program year. The agency also releases subsequent guidance during the reporting period, leaving physicians little time to educate themselves and their staff on changes.
- Conflicting requirements not under physicians’ control. Reporting options outside of claims, such as registry, electronic health record (EHR) and group practice reporting option (GPRO) are much different than claims. Physicians are at the mercy of vendors to submit information correctly and at the mercy of CMS to have the capability to accept the data.
- Reporting period challenges. The period of reporting time to avoid a penalty under the eRx program was only six months—not enough time to report, which has exposed physicians to financial penalties.
“Physicians already are facing numerous obstacles, outside of their control, that limit their chance of success in these programs,” the letter said. “By adding an audit process, which spans over four years, CMS is creating yet another barrier to successful participation.”
The AMA said in the letter that it “unequivocally condemns true fraud,” but the audit program will be challenging to administer. “Physicians may decide to drop out and take a financial penalty rather than expend significant time and resources attempting to comply and risk being faced with possible burdensome and time-consuming audits,” the letter said.
The AMA recommends CMS invest in resources to support physician participation in quality programs and new care delivery models.
The letter came on the heels of another communication the association sent to CMS on May 2, urging the agency to make the current PQRS requirements more flexible to avoid the 2016 penalty. The AMA also advised CMS to better align its quality programs, including the meaningful use EHR program and the value-based modifier program. The AMA requested that physicians who meet meaningful use standards be exempt from PQRS and subsequently advised physicians who meet PQRS be exempt from meaningful use quality reporting.
“Unless CMS adopts certain modifications that would enhance the ability to meet the PQRS reporting requirements, we are concerned that many physicians, particularly those in small practices and rural areas, will face payment penalties in 2016 (and beyond) despite their good faith efforts to participate in the PQRS program,” that May 2 letter said.
