Reporting Periods

AMA supports the agency’s proposal to retain 2010 PQRI reporting periods for FY 2011. CMS proposes to retain the claims-based reporting mechanism for 2011, but notes that the agency continues to consider significantly limiting the claims-based mechanism of reporting clinical quality measures in future program years. This limitation continues to be contingent upon there being an adequate number and variety of registries available and/or the continuation/expansion of the electronic health record (EHR) reporting option. Potentially, CMS would continue to retain claims-based reporting in years after 2011 principally for the reporting of structural measures and in circumstances where claims-based reporting is the only available mechanism for certain categories of physicians to report PQRI quality measures. The AMA encourages CMS to be cautious in how it determines to phase-out the claims-based reporting option until it is abundantly clear that all physicians understand and are able to consistently and accurately capture quality measures using EHRs or registries.

CMS must also consider whether the eventual elimination of claims-based reporting would unnecessarily penalize physicians who do not own an EHR or participate in a registry because of extenuating circumstances, e.g., small, rural providers lacking digital connection. The availability of a claims-based reporting option enables most physicians to participate in the PQRI without incurring significant technology. Transitioning away from claims-based reporting too quickly, without consideration of the small or rural provider, could inappropriately burden physicians who are making a good faith effort to report measures for quality improvement.

Regardless of the reporting mechanism, CMS should provide developers of measures utilized in the PQRI with support to carry out validity and reliability testing of measures. The AMA Physician Consortium for Performance Improvement (PCPI) has significant experience in testing quality measures in various platforms and would be a valuable resource as CMS continues to evaluate all reporting options for the PQRI.