CMS proposes to post on the PQRI section of the CMS Web site a list of qualified registries for the 2011 PQRI, including the registry name, contact information, and the 2011 measure(s) and/or measures group(s) and e-prescribing reporting (if qualified) for which the registry is qualified and intends to report. At the February 2, 2010, PQRI Listening Session, the AMA and other attendees recommended that CMS post additional registry information including cost to participate; number of past or current participants; frequency of registry feedback reports; and success rate of participants. CMS did not reflect these comments in the proposed rule, and the AMA urges CMS to seriously consider these recommendations and include these additional topics of information to better assist physicians in selecting a registry most appropriate for their practice. In addition, the AMA recommends that PQRI participants have an opportunity to file complaints directly with CMS regarding particular registries.
As discussed in the proposed rule, CMS continues to be concerned that an individual physician or a small practice does not have either the resources or the capabilities to successfully submit quality measures results and numerator and denominator data on PQRI individual measures or measures groups through the registry data submission process. The AMA shares this concern, which is why we continue to have reservations about the requirement that physicians must meet all 15 core measures (including clinical quality measure reporting) and five additional measures from a defined menu in order to qualify for meaningful use (MU) program incentives.
The PCPI seeks to test its measures across a variety of Medicare incentive programs using different data sources, and has a long-established protocol to conduct such testing. Our difficulty has been identifying practice sites that participated in PQRI claims reporting for a complete year on specific measurement sets, and who have the capacity to participate in a testing project. It appears the qualified registries may have such information readily available and be in a position to collaborate with the PCPI on testing quality measures. The AMA welcomes an opportunity to discuss quality measures testing with CMS and the qualified registries.