Deadline for Seeking Review of Potential Payment Penalties

Late last month, the Centers for Medicare and Medicaid Services posted information on its website that physicians can consult to determine whether they will be subject to 2017 payment penalties associated with the Physician Quality Reporting System (PQRS) and the Value Modifier. Physician practices that have concerns about the findings in their report(s) have until November 30 to file for an informal review of their data.

These penalties stem from policies in effect prior to the enactment of the Medicare Access and CHIP Reauthorization Act. Failure to successfully complete required PQRS reporting will result in a 2 percent penalty. Value Modifier penalties can range from 1 percent to 4 percent depending on the size of the practice and its performance on cost and quality measures. PQRS penalties will be communicated to physicians by mail as well as in the PQRS feedback reports posted on the CMS website. Value Modifier penalties and bonuses can be found in Quality and Resource Use Reports (QRURs) posted on the website only.

Additional information on accessing the reports and filing for an informal review can be found in the attached documents. Those who have questions, even if they are uncertain about penalty status, are urged to submit a request for informal review. Although in most cases a successful PQRS review will trigger an automatic review of related VM penalties, program officials say the safest course is to file requests for review of both PQRS and VM data.

Follow these steps to submit an informal review request:

1. Go to the Quality Reporting Communication Support Page (CSP)
2. In the upper left-hand corner of the page, under “Related Links,” select “Communication Support Page”
3. Select “Informal Review Request”
4. Select “PQRS Informal Review”
5. A new page will open
6. Enter Billing/Primary Taxpayer Identification Number (TIN), Individual Rendering National Provider Identifier (NPI), OR Practice Site ID # and select “submit”
7. Complete the mandatory fields in the online form, including the appropriate justification for the request to be deemed valid. Failure to complete the form in full will result in the inability to have the informal review request analyzed. CMS or the QualityNet Help Desk may contact the requestor for additional information if necessary.

Please see “2015 PQRS: 2017 PQRS Negative Payment Adjustment — Informal Review Made Simple” available on the PQRS Analysis and Payment webpage for more information.

NOTE: The CSP will be unavailable November 18-20 for maintenance.

Additionally, 2015 PQRS feedback reports can be accessed on the CMS Enterprise Portal using an Enterprise Identity Management (EIDM) account. For details on how to obtain your report, please see the “Quick Reference Guide for Accessing 2015 PQRS Feedback Reports.” For information on understanding your report, please see the “2015 PQRS Feedback Report User Guide.” Both guides are on the PQRS Analysis and Payment webpage.

For additional questions regarding the informal review process, contact the QualityNet Help Desk at 1-866-288-8912 (TTY 1-877-715-6222) or Qnetsupport@hcqis.org Monday-Friday from 7:00 a.m. to 7:00 p.m. CT. To avoid security violations, do not include personal identifying information, such as Social Security Number or TIN, in e-mail inquiries to the QualityNet Help Desk.