The Physicians Quality Reporting System prior to 2010 only accommodated reporting by individual eligible professionals (EPs) through specified reporting channels. In 2010, through the enforcement of section 1848(m) (3) (C) of the Social Security Act (the Act), the Centers for Medicare and Medicaid Services (CMS) added a group practice reporting option (GPRO) to the PQRS program that opened the doors for group practices to do their reporting as a group rather than individual EPs. With the addition of the GPRO option, it is now essential for EPs to determine whether to do their reporting as individual EPs or through the GPRO. To help you understand each, below we’ve outlined the three major differences between each and how to participate in either one.
Constitution
An individual EP is defined by the CMS as a medical practitioner with an individual National Provider Identifier or NPI qualified to practice under any one of a number of specialties including medicine or osteopathy, dental surgery or dental medicine, podiatry, optometry and chiropractic medicine. On the other hand, a practice that seeks to report its PQRS measures through the GPRO must comprise a minimum of 2 eligible professionals (defined by the same parameters as above) practicing under one group practice as defined by a single Tax Identification Number (TIN) and who have reassigned their billing rights to that TIN. If you belong to a group practice then it’s best to apply to the CMS as a group through the Physician Value-Physician Quality Reporting System (PV-PQRS) registration system to be added to the list of qualifying practices under the GPRO.
Reporting Options
While reporting options between individual EPs and group practices have similarities, there are some differences that could impact the overall success rate at which you undertake reporting. For instance, while as an Individual EP you can simply go ahead and start reporting as soon as you verify that you qualify, groups must first consolidate their practice under one TIN number, then they’ll need to have billed Medicare Part B PFS on or after January 1, 2014 and prior to December 31, 2014 among other criteria. In addition, the group practice will need to have at least 25 members in order to utilize the additional reporting channels available to GPRO-qualified practices including GPRO Web Interface Reporting and CMS-Certified Survey Vendor reporting. Each reporting option offers its unique merits but the important thing to note when it comes to reporting is that it makes better sense to report as a group when your practice qualifies for GPRO reporting.
Measures to Report
As an individual EP, the threshold of reporting isn’t as high as for group reporting owing to the recognition by the CMS that your practice may cater to a very narrow band of measures domains. As a result, individual EPs are only required to report 1-3 measures falling under at least one domain for a minimum of 50% of all patients seen in that year to meet the compliance threshold. For group practices, this threshold is enforced but in addition, the group practice must report between 1 and 8 measures across 1-3 domains for 50% of all cases seen in that year. For both individual EPs and group practices, the Measure-Application Validation (MAV) process will be undertaken by the CMS in the event that sub-threshold measures are reported.
As a rule of thumb, individual EPs have to undertake a greater level of compliance establishment compared to a group as the individual must meet close to the same threshold of requirements as a group practice. That said, the GPRO route is essential for any practice with two or more EPs that plans to grow and diversify over the years while still maintaining compliance with the EHR PQRS Incentive specifications.
