The Centers for Medicare and Medicaid Services published the Final Rule for the Physician Fee Schedule on November 13, 2014. This Final Rule addresses changes to physician payment under the Medicare program that took effect on January 1, 2015. Specifically, the Final Rule details changes to the Physician Quality Reporting System (PQRS), Physician Compare website, and the Value-Based Payment Modifier, among other changes. Find the comments to the Final Rule submitted by IDSA here. IDSA expressed to CMS its concerns over how performance data will be presented to the public, including the potential use of national benchmarking, which may not take into account regional variation in practice patterns and differences in patient populations. For example, there are regional variations in the causes of pneumonia (specifically Legionellosis) and holding providers to a rigid national standard may not serve Medicare beneficiaries’ best interests.
Further, the comments outlined IDSA’s concerns that due to the paucity of measures that can be reported via claims-based reporting, many of our members in solo/small practices may face the potential administrative burden and anxiety of being subject to the measure-applicability validation (MAV) process since most claims-based measures that even remotely apply to the clinical practice of infectious disease medicine lie in the Effective Clinical Care domain or the Community/Population Health domain.
IDSA continues to work to build a robust portfolio of relevant quality measures that will allow our members to demonstrate their value in the treatment of severe infections, such as Clostridium difficile-associated enterocolitis and Staphylococcus aureus septicemia. In its comment letter, IDSA requested that CMS recognize these ongoing efforts by more gradually retiring measures from the PQRS so that specialties are not left scrambling to find less than meaningful ways to satisfy reporting requirements at the “11th hour.” Alternatively, or in parallel, IDSA requested that CMS offer more flexible reporting options for those who do not have a large number of relevant measures to report.
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