This December, two months from now, all the 2015 quality data reported by any eligible provider (collected by any mechanism) will be made public by the Centers for Medicare and Medicaid Services (CMS). If you are a hyperbaric medicine or wound care practitioner who bills Medicare patients and submitted data to the Physician Quality Reporting System (PQRS) in the specified time frame, your quality performance data will be publicly visible on Physician Compare. https://www.medicare.gov/physiciancompare/search.html
CMS was required by the Affordable Care Act to establish the Physician Compare website. Since it launched in 2010, CMS has been trying to include on the website more useful information about physicians and other healthcare professionals who participate in Medicare. Medicare believes that making performance data public can improve care for Medicare beneficiaries and is a way for providers to demonstrate their commitment to quality care. As a result, their 2 main goals for Physician Compare are to: 1) encourage consumers to make more informed choices based on quality performance data and, 2) incentivize physicians to maximize their performance in quality programs. Currently, the site has information on providers who participate in Medicare including name, specialty, address, board certification(s), education, residence, hospital affiliation, gender, and whether the provider reported quality measures (QMs) or uses an electronic health record (EHR). https://www.medicare.gov/physiciancompare/staticpages/data/aboutthedata.html
To be listed on the Physician Compare website, a healthcare professional must be in an approved status in PECOS (the Provider Enrollment, Chain and Ownership System) for Medicare, provide at least one practice location address, have at least one specialty noted, and have submitted a Medicare fee for service claim within the last 6 months. It’s possible to search for health care professionals and practices within a certain location by name, medical condition or specialty. That means it is NOT possible to search for a physician involved in wound care because it’s not a specialty.
Performance Data and Public Reporting
The Physician Compare website has gradually been adding data from the Physician Quality Reporting System (PQRS), beginning with group practices in 2014. The website has always seemed very primary care focused, but then, that’s the way PQRS works. Data reported in 2014 was on general health (e.g. flu shot, pneumonia vaccination), cancer screening, heart disease, diabetes and patient safety. Here are the measures:
Getting a flu shot during flu season
- Making sure older adults have gotten a pneumonia vaccine
- Screening for depression and developing a follow-up plan.
- Screening for tobacco use and providing help quitting when needed
- Screening for an unhealthy body weight and developing a follow-up plan
- Screening for high blood pressure and developing a follow-up plan.
- Screening for breast cancer
- Screening for colorectal (colon or rectum) cancer
- Comparing new and old medications
- Controlling blood pressure in patients with diabetes
- Using aspirin or prescription medicines to reduce heart attacks and strokes in patients with diabetes
- Patients with heart failure and a weakened pumping chamber of the heart who got a beta blocker
- Prescribing medicine to improve the pumping action of the heart in patients who have both heart disease and certain other conditions
- Using aspirin or prescription medicines to reduce heart attacks and strokes
It’s important to remember that the audience for the Physician Compare website is the consumer (e.g. patients). Additional quality data files are available for download which may be used by payers or other entities. Any PQRS measure MAY be reported, but CMS decides exactly which measures to report based on published public reporting standards and the federal rule making process. Measures must pass various tests of statistical validity and there is a 20-patient minimum threshold for every measure. Measures that meet those criteria are turned over to the Physician Compare Support team which develops plain language titles and descriptions for them, after which CMS conducts consumer testing of the measure. Consumer testing not only assesses whether consumers understand the information that the measures is supposed to convey, but whether the data would help them choose a healthcare provider. Interestingly, if a measure meets all of the public reporting standards EXCEPT the requirement that it resonates with consumers, the measure data may be added to the downloadable database, but it will not be included on the website for public viewing. https://data.medicare.gov/data/physician-compare
I am not sure that this point can be over-emphasized. That’s an interesting thing to ponder if you are a podiatrist or wound care clinician who succeeded with PQRS thanks to the diabetes measure group (for example) which has no direct relevance to wound care and little relevance to podiatry other than the foot assessment of diabetics.
What is the Achievable Benchmark of Care (ABCTM) ?
A benchmark helps consumers understand the context for measure performance rate by providing a point of comparison to other clinicians. Item level measures have to have a benchmark “passing rate” and these are created using the Achievable Benchmark of Care (ABC) methodology. CMS ranks healthcare professionals from highest to lowest performance score for a specific measure. It then selects the subset of top healthcare professionals representing at least 10% of the eligible PATIENT population for the measure, and calculates the number of patients receiving the intervention or desired level of care for that measure. It then divides the number of patients by the total patient population for the top doctors to calculate the benchmark. That means that the benchmark is specific to each measure. The earliest benchmark will be reported in late 2017. CMS will take these benchmarks and then devise a way to create “5 star ratings” for providers based on these benchmarks.
Why this matters to wound care practitioners
This is yet another reason why wound care clinicians should consider moving away from standard PQRS measures or the diabetes measure group (which is being reported by endocrinologists and internists) to measures that are relevant to their practice. The ABC method means: 1) you are graded on a “curve” based on the other providers reporting that measure, and 2) you are going to end up with a “star rating” based on the measures you are reporting. So, a wound care clinician or a podiatrist could end up being (for example) a “one star” provider simply because they are performing on the low end of the spectrum in a set of quality measures that are not even relevant to their practice and which they were reporting just to “get through PQRS” to avoid a financial penalty. I call this measuring how well a fish can ride a bicycle. A wound care practitioner may score poorly at blood pressure control and BMI follow up in comparison to an endocrinologist whose job it is to manage these things, despite being a fantastic wound care practitioner.
That’s why reporting wound care specific quality measures like those offered by the US Wound Registry (USWR) are a better alternative in the long run https://www.uswoundregistry.com/Specifications.aspx. At least a wound care practitioner can report measures relevant to their practice. By late 2017, Qualified Clinical Data Registry (QCDR) measures will also be reporting item benchmarks. If you want to see a list of forward thinking eligible wound care providers, then in December, check out the clinicians who reported USWR wound care quality measures. Their quality data will be posted on the USWR website (https://www.uswoundregistry.com/). It won’t just be patients who are looking at those quality data to select the best wound care practitioner. Private Payers will use this information to decide where to send their patients.
There’s another advantage to reporting wound care measures through the USWR. Wound care isn’t a specialty and since the American Board of Medical Specialties will not be granting any new primary specialties, the only way for wound care practitioners to be identified AS wound care practitioners is to report the same quality measures. If wound care practitioners were to all report the USWR quality measures, then suddenly we will have done the next best thing to creating a specialty – we will have created a specialty measure group for wound care. Hyperbaric medicine practitioners should be reporting the HBOT measures developed by the UHMS.
Caroline Fife, MD
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