Physician Quality Reporting System: No New Anesthesiology Measures for 2011

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Editor's note: This article by Tony Mira, president and CEO of Anesthesia Business Consultants, an anesthesia & pain management billing and practice management services company, originally appeared in Anesthesia Business Consultants eAlerts, a free electronic newsletter. Sign-up to receive this newsletter by clicking here.

The 2011 Physician Quality Reporting System (PQRS, the new name for the Physician Quality Reporting Initiative [PQRI], as announced in the Federal Register notice containing the final Fee Schedule rule) does not contain any new anesthesia measures. Next year, anesthesiologists and nurse anesthetists who perform the measures will continue to be able report the following on their Medicare claims:

Measure #30: Perioperative Care: Timely Administration of Prophylactic Parenteral Antibiotics

DESCRIPTION: Percentage of surgical patients aged 18 years and older who receive an anesthetic when undergoing procedures with the indications for prophylactic parenteral antibiotics for whom administration of the prophylactic parenteral antibiotic ordered has been initiated within one hour (if fluoroquinolone or vancomycin, two hours) prior to the surgical incision (or start of procedure when no incision is required).

Measure #76: Prevention of Catheter-Related Bloodstream Infections (CRBSI): Central Venous Catheter (CVC) Insertion Protocol

DESCRIPTION: Percentage of patients, regardless of age, who undergo CVC insertion for whom CVC was inserted with all elements of maximal sterile barrier technique [cap AND mask AND sterile gown AND sterile gloves AND a large sterile sheet AND hand hygiene AND 2 percent chlorhexidine for cutaneous antisepsis (or acceptable alternative antiseptics per current guideline)] followed.

Measure #193: Perioperative Temperature Management

DESCRIPTION: Percentage of patients, regardless of age, undergoing surgical or therapeutic procedures under general or neuraxial anesthesia of 60 minutes duration or longer, except patients undergoing cardiopulmonary bypass, for whom either active warming was used intraoperatively for the purpose of maintaining normothermia, OR at least one body temperature equal to or greater than 36 degrees Centigrade (or 96.8 degrees Fahrenheit) was recorded within the 30 minutes immediately before or the 15 minutes immediately after anesthesia end time.

The full sets of coding instructions and references for the above measures begin on pp. 81, 176, and 447, respectively, of the 2011 Physician Quality Reporting System (Physician Quality Reporting) Measure Specifications Manual for Claims and Registry Reporting of Individual Measures. The manual includes the specifications for all 194 measures in the 2011 PQRS. Each measure specification encompasses the following:

Measure Specification Format
Measure title
Reporting option available for each measure (claims-based or registry)
Measure description
Instructions on reporting including frequency, timeframes, and applicability
Denominator statement and coding
Numerator statement and coding options
Definition(s) of terms where applicable
Rationale statement for measure
Clinical recommendations or evidence forming the basis for supporting criteria for the measure

The three anesthesiology measures can be reported on individual claims or, theoretically at least, through a registry. Thus far, though, there are no qualified registries, to the best of our knowledge, that can transmit PQRS data in the requisite format. The Anesthesia Quality Institute is in the process of obtaining certification for the National Anesthesia Clinical Outcomes Registry, and we will provide further information as soon as the AQI makes it available. Readers who want to verify whether a particular entity is eligible to submit their quality data to CMS may consult the list published in June 2010, Qualified Registries for the 2010 PQRI and Electronic Prescribing Incentive Programs. Note that many of the registries that have listed "All Measures" in the column headed "Individual Measures Registry is Planning to Report" cannot, in fact, report Measures #30, #76 and/or #193.

EHR-Based Reporting

Medicare incentivizes the adoption of electronic health records (EHRs) through two separate, independent and cumulative programs. One is the American Recovery and Reinvestment Act's (ARRA's) Health Information Technology for Economic and Clinical Health (HITECH) Act's EHR Incentive Program – which we are not reviewing here, having last addressed it in our Alert of April 26, 2010. The other is PQRS Measure #124, which has been significantly updated for 2011.

Measure #124: Health Information Technology (HIT): Adoption/Use of Electronic Health Records (EHR)

DESCRIPTION: Documents whether provider has adopted and is using health information technology. To report this measure, the eligible professional must have adopted and be using a certified, Physician Quality Reporting System qualified or other acceptable EHR system.

Measure #124 can only be reported together with an office or other outpatient visit (CPT™ codes 99201-99215). The initial and subsequent hospital care codes (99221-99236) do not figure into the denominator for #124. This measure is thus of much more potential interest to pain specialists than to surgical anesthesiologists.

CMS recognizes that there are few certified or PQRS-qualified EHRs, but it wants to encourage the rapid adoption of existing information systems that will ultimately "enhance the care of individual patients by providing timely reminders about needed services and summarized data to track and plan care. At the practice population level, they identify groups of patients needing additional care, as well as facilitate performance monitoring and quality improvement efforts." Accordingly, CMS has defined the numerator codes, G8447 and G8448 to apply to "Patient encounters with documentation substantiating the use of a certified, Physician Quality Reporting System qualified or other acceptable EHR system during the measurement period." (Emphasis added). EHRs may be deemed acceptable if they include the data elements listed in Appendix A to the 2011 EHR Measure Specifications:

What other PQRS measures are available to pain specialists? The two tobacco use measures (#114 - Preventive Care and Screening: Inquiry Regarding Tobacco Use; #115 - Preventive Care and Screening: Advising Smokers and Tobacco Users to Quit) have both been deleted and should not be reported effective January 1, 2011. Neither Measure #128 - Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up nor Measure #131 - Pain Assessment Prior to Initiation of Patient Therapy and Follow-Up fit a normal pain practice. On the other hand, the measure that seeks to ensure safe medication practices in the ambulatory setting may be applicable:

Measure #130: Documentation of Current Medications in the Medical Record

DESCRIPTION: Percentage of patients aged 18 years and older with a list of current medications (includes prescription, over-the-counter, herbals, vitamin/mineral/dietary [nutritional] supplements) documented by the provider, including drug name, dosage, frequency and route

We refer you to the Measure Specifications Manual hyperlinked above, and to its companion 2011 Physician Quality Reporting System (Physician Quality Reporting) Measure Specifications Manual for Claims and Registry Release Notes for further information on current specifications for measures that may be relevant to your practice.

We would like to emphasize that anesthesiologists and pain physicians will continue to be eligible for the PQRS bonus even if they report fewer than three measures, because of the same "Measure Applicability Validation" (MAV) process that has been in effect for several years.

The MAV Test: One or Two Measures May Suffice

The MAV process determines whether a provider who has reported fewer than three PQRS measures, the nominal minimum, may nevertheless qualify for the bonus. In order to determine whether the physician could have reported more measures, the MAV applies a clinical relationship test and a minimum threshold of encounters. Clinical relatedness depends on whether there are multiple measures in the relevant "cluster" of measures listed in the 2011 Physician Quality Reporting System Measure-Applicability Validation for Claims-Based Reporting of Individual Measures. The two anesthesia clusters indicate that it will once again suffice to report:

• Measure #30 and Measure #76, or
• Measure #193 and Measure #76, or
• Measure # 76 alone.

The 2011 MAV paper also provides explicitly that Measures #124 (EHR) and #130 (Documentation of Medications) are not subject to the MAV process. Thus anesthesiologists, whether they practice in the OR or in a pain clinic, may qualify for the 2011 PQRS bonus – 1.0 percent, not the 2.0 percent allowed in 2009-2010 – if they report one or two of the measures discussed above in at least 50 percent (80 percent in 2009-2010) of their eligible cases.

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The information provided should be utilized for educational purposes only. Please consult with your billing and coding expert. Facilities are ultimately responsible for verifying the reporting policies of individual commercial and MAC/FI carriers prior to claim submissions.