Some claims for services provided in early June will have been paid at the lower rate of $16.6058 (or more precisely, at the applicable rate adjusted for differences in the Medicare geographic practice cost indices). The “Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010,” signed into law on June 25, retroactively postponed the 21.3% SGR cut until December 1st and established a 2.2% payment update.
Your local Medicare Administrative Contractors (MACs) should be adjusting, automatically, any claims paid at the now-invalidated lower rate. No one knows whether Congress will take action in time to stop the SGR cut from going into effect in December or from mandating a further 6.1% reduction in Medicare payments in 2011. Please keep up the pressure on your Senators and Representatives.
Another possible income opportunity: the PQRI bonus for MOCA participation
We have received some reader questions about qualifying for the additional 0.5% PQRI bonus for participating in an approved maintenance of certification program. A bullet point in the July 6th Alert mentioned the bonus, which CMS discussed at length in the proposed Medicare Fee Schedule Rule for 2011 (pdf). This is one of the many innovations of the Patient Protection and Affordable Care Act that we will feature in upcoming ABC Alerts.
The basic principle is that under the PQRI, an additional bonus payment of 0.5% per year, beginning in 2011, is available to physicians who:
- Participate in a maintenance of certification (MOC) program required for board certification by a recognized physician specialty organization for at least one year,
- Complete a MOC practice assessment, and
- Otherwise report PQRI measures successfully.
The American Board of Anesthesiology offers a MOC-Anesthesiology (MOCA) program in which ABA diplomates who obtained time-limited certification in 2000 and subsequent years must participate, and in which diplomates certified before 2000 may participate. MOCA is a 10-year program; boarded anesthesiologists with a time-limited certificate must complete the requirements before their current certification expires in order to maintain their diplomate status.
To qualify MOCA for PQRI purposes, the ABA, like all the certifying organizations, will need to formally nominate the program to CMS by January 31, 2011 and receive CMS approval. As part of the nomination process, CMS has proposed that the ABA will need to include the following in its self-nomination letter:
- The duration and frequency of a cycle;
- The first year of availability of the MOCA practice assessment;
- Data collected under the patient experience of care survey
- Method of monitoring that a diplomate has implemented a quality improvement process for his or her practice; and to
- “Describe the methods, and data used under the [MOCA], and provide a list of all measures used in the [MOCA] for 2010 and to be used for 2011, including the title and descriptions of each measure, the owner of the measure, whether the measure is NQF [National Quality Forum] endorsed, and a link to a website containing the detailed specifications of the measures, or an electronic file containing the detailed specifications of the measures.”
MOCA consists of four elements that are fully described on the ABA website and that need only be listed here:
- Professional Standing Assessment
- Lifelong Learning and Self-Assessment
- Cognitive Expertise Assessment, and
- Practice Performance Assessment.
These elements include the critical practice assessment and quality improvement, but nothing on the ABA website points to any patient-experience survey or to specific performance measures such as the PQRI measures endorsed by the NQF. We anticipate, however, that the ABA will likely obtain the requisite approval for MOCA based on two factors: (a) the PQRI requirements are subject to public comment and refinement before they are finalized, and anesthesiology leadership is probably going to weigh in so that MOCA will qualify, and (b) the ABA may well already be preparing to survey patient experience as well as to capture performance measurement data. (Whether the ABA itself opts to create a registry through which anesthesiologists can submit their PQRI information to CMS instead of including PQRI codes on every Medicare claim remains to be seen, given the progress in that direction of the Anesthesia Quality Institute organized under the ASA.)
Assuming that MOCA seeks and receives CMS approval, the ABA will additionally have to provide CMS, by March 31, 2012, with the names and NPIs of each anesthesiologist who would like to participate and receive the 2011 bonus, and attest that s/he has met the individual PQRI-MOC requirements.
The PQRI-MOC requirements for individual ABA-certified anesthesiologists are:
- Successfully participate in a qualified MOC practice assessment “more frequently than in necessary to maintain board certification.” That means that if the anesthesiologist has not had to do a practice assessment for the MOCA previously, s/he will have to do one in 2011. If that anesthesiologist has already done the practice assessment during his or her certification cycle, s/he will have to do another one in 2011 to meet the “more frequently” standard, and
- Successfully participate in the MOCA for 2011.
Thus the MOCA program’s qualifying is not automatic, and no physicians will be eligible for the 0.5% bonus merely because they are maintaining their certification through their specialty board. If the ABA’s MOCA is approved after it self-nominates, every anesthesiologist hoping to earn the bonus will need to do the practice assessment in 2011. Even a diplomate whose board certification is not time-limited, or one who must be recertified or is first certified in 2010, will need to complete the practice assessment – and will also need to report the regular PQRI measures successfully over the full 12 months of the calendar year. It is important to remember that underlying condition, and also to note that the MOCA bonus incentive will only be available for the years 2011-2014.
Some of these details are subject to change because CMS has just published the proposed rule for public comment. The central role of the MOCA itself and the “more frequently” requirement are in the statute so those will still be there after CMS finalizes the regulations, but the details of reporting on patient experience and each MOC program’s own performance measures will not be finalized until November at the earliest. The only action we recommend that you take now is to avoid banking on the MOCA payment while watching for further developments on earning that 0.5 percent bonus.
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