Why I Don’t Participate in PQRI: Let Me Count the Ways

Dr. Bachelder is a practicing family physician in Mount Gilead, Ohio, and is a member of the AAFP Commission on Quality.

When CMS rolled out its Physician Quality Reporting Initiative, or PQRI, in 2007, I elected not to participate. Here’s why:

Pay. My 2006 Medicare income was $33,250. To estimate the PQRI payment, I multiplied by 1.5 percent, and then by 50 percent (for the six-month reporting period). The result shows that I might earn up to $250 -- actually less, because some of that $33,250 was for laboratory payments, and PQRI only covers services paid under Medicare’s Physician Fee Schedule. If I perform three measures on my 30 Medicare diabetic patients, then I will be paid about $2.77 per measure. The rewards don’t cover the administrative costs.

Hassle Factor. I use an electronic medical record, or EMR, but additional work will be needed whether the practice is on EMR or still uses paper. Larger practices may have the economy of scale to financially justify performing PQRI, but smaller practices may not.

Synchronous Submissions. Measure results must be submitted simultaneously with the office visit charges. You can’t submit the information later unless the patient returns for another charged office visit.

Data Accuracy. The data is not aggregated, analyzed or reviewed by an independent third party. There is no corroboration of the information. This is important despite CMS’ reassurance that the data will not be released to the public at the individual or group practice level.

Appeals Process. If CMS denies a PQRI payment, there is no appeals process.

Payments. CMS will pay for the information in mid-2008. This is not timely.

Data Feedback. Physicians are unable to access the submitted information and peer comparisons in real time. In fact, access will not be available until mid-2008.

Registries. Although the most efficient method for data submission would be the use of a registry embedded within an EMR (I have this capability), CMS does not allow for it. The program needs to minimize the administrative, financial and technological barriers to participation.

Data Value. Beyond the issue of payment to cover the cost of data collection is a consideration of the true value of the data. CMS should recognize this inherent value and reimburse more appropriately.

RHCs and FQHCs. PQRI covers only services paid under Medicare’s Physician Fee Schedule. Clinical lab services; rural health clinics, or RHCs; and federally qualified health clinics, or FQHCs, do not qualify. I am part of an RHC.

Many of the points made above come directly from AAFP’s policy on pay for performance. It is understandable that the AAFP is supportive of CMS’ program. Our organization needs to be at the table to promote positive changes. However, as individuals we can have an impact by choosing not to participate. This passive resistance by many may send a loud message to CMS that the present flaws in PQRI are too great to be overcome by any justification for data submission.