2 Providers Reporting for Your ENTIRE Practice... Really?!?!?!
It happens in every practice. One or two docs don’t feel charting is important. It’s an ivory tower attitude. It’s as if Yoda himself proclaimed: “Most important, patient care is.” And to be honest, as a doc, it’s more than a little insulting as the implication is that patient care is somehow NOT the priority of the providers trying to comply with the federal documentation guidelines, the clinical algorithms, preferred drug lists, and now the CMS Quality Payment Program (QPP). While noncompliance may negatively impact revenue, disinterest in, or cumbersome compliance with the QPP reporting metrics no longer needs to be a stressor.
In 2017 any practice with more than two providers—yes, just two!—can report using just two providers. Even if you have 40, 50, or 100+ providers, successfully reporting on just two (in their specialties) can avoid penalty and potentially result in a partial or full bonus! To be clear, the practice’s QPP success lives and dies by those two providers; i.e., those two perform well and the whole practice benefits but negative performance means the whole practice loses. As such, the optimal performance of these two becomes paramount or the entire practice suffers a 4% payment reduction in 2019.
This is yet another gift from CMS for not all providers are non-compliant on principle. Some providers have very FEW metrics on which they can report due to their unique specialty, practice focus, or geographic proximity. For the latter, think home health or telehealth providers or even electrophysiologists and pathologists.
In contemporary clinical medicine, direct patient care is not what everyone does in medicine. Throughout the history of healthcare, we have all met docs who really should not communicate with patients—think Dr. House redirected to computer based consulting to optimize brilliance without affecting patient dignity. Dr. House would have nowhere to report. However, two of his colleagues… the two best and most optimally reporting providers… help the entire practice avoid penalty and achieve bonus. It is a no-brainer for those paying attention to the rules.
Despite this tremendously positive loop hole, the other providers should still optimize real time reporting and compare specialty specific metrics to keep up to speed with how their clinical data compares to their peers. That’s the intent of the QPP and basis the quality reporting program since inception; i.e., to save avoidable expense by adopting best clinical practices and not wasting money on procedures or medical care that could be avoided.
Finally, remember, this is the government running this program. Governments impose taxes and financial penalties to modify the behavior of citizens. The QPP rules will morph to compel larger and larger volumes of providers to report individually. Loopholes will become fewer and like it or not, providers will have to learn how to win at the latest game. Getting a head start by preparing before it is mandated will help your practice detect and correct issues without being penalized. Your two best providers will save the day for the practice as the others get up to speed.
About the author
Douglas J. Jorgensen, DO, CPC, FAAO, FACOFP, CAQ Pain Medicine, is founder and owner of Patient360 (a Medicare-approved PQRS entity), which was one of the original private registries when the physician quality reporting program began. He lectures nationally on billing and coding issues, as well as authors articles for peer reviewed medical journals and national newsletters. In addition to litigation consultancy and expert witness work, Jorgensen consults for the FBI, Drug Enforcement Administration, and the Office of Inspector General. With his twin brother, Ray Jorgensen, CPC, he released a best-selling healthcare reimbursement guide, “A Physicians Guide to Coding and Billing.” Jorgensen is a member of the Lewiston, Maine, local chapter.