Eli's Rehab Report

Eligible providers await a penalty of -1.5% in 2015 for nonparticipation.

Voluntary incentive programs are all good ... until they fall off your radar and suddenly become required. This will soon be the case for Medicare's Physician Quality Reporting System (PQRS). If you are in private practice and bill Medicare using an individual-level National Provider Identifier (NPI), you are eligible to participate in PQRS -- and need to get involved no later than 2013.

PQRS encourages eligible providers to report on their claims when they perform certain quality measures CMS lists for each discipline in each year's Medicare Physician Fee Schedule. If you report enough quality measures as required by CMS, you receive a bonus of 0.5 percent.

Tables turned: The Affordable Care Act mandated that PQRS move from an incentive program to a "payment adjustment" program in 2015, in which CMS will stop giving bonus payments and, instead, instill a penalty for non-participation.

That's not all: In last year's Medicare Physician Fee Schedule rule, CMS decided to go retroactive to determine your penalty -- and this year's proposed rule affirmed this decision. "The 2015 deductions applied to people not participating are going to be based on 2013 participation," says Lisa Satterfield, director of health care regulatory advocacy for the American Speech-Language Hearing Association.

If eligible providers do not successfully report their PQRS measures in the 2013 calendar year, they will see a 1.5 percent payment deduction in 2015, Satterfield explains. Likewise, if they do not successfully report their PQRS measures in 2014, they will receive a 2 percent deduction in 2016.

Good news: "You only need to report on one measure for 80 percent of the eligible patients to avoid that deduction in 2015," Satterfield says.

"Our biggest concern right now is for people in private practice who are unaware of the major changes about to take place in the program conversion and the use of the 2013 data to inform the 2015 penalty," says Heather Smith, program director of quality for the American Physical Therapy Association.

Startling: In the 2010 PQRS reporting year, only 16 percent of all eligible PTs and OTs participated, Smith points out. "That is very low participation, and there are tremendous concerns around getting the word out to educate eligible therapists to start reporting next year."

For more information on PQRS, visit www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/index.html?redirect=/pqrs.