Public Reporting of PQRI Data

The ACA requires the Secretary of HHS to develop a Physician Compare Internet Web site by January 1, 2011, on which information on physicians enrolled in the Medicare program and who participate in the PQRI program would be posted. CMS proposes for the 2011 PQRI to use the current Physician and Other Health Care Professional Directory as a foundation for the Physician Compare Web site. As with the 2010 PQRI, CMS will continue to make public the names of physicians and group practices that satisfactorily submit quality data for the 2011 PQRI. Specifically, CMS proposes to post the names of physicians who: (1) submit data on the 2011 PQRI quality measures through one of the reporting mechanisms available for the 2011 PQRI; (2) meet one of the proposed satisfactory reporting criteria of individual measures or measures groups for the 2011 PQRI as described above; and (3) qualify to earn a PQRI incentive payment for covered professional services furnished during the applicable 2011 PQRI reporting period, for purposes of satisfying the requirements on the Physician Compare Web site.

Similarly, for purposes of publicly reporting the names of group practices, on the Physician Compare Web site, for 2011, CMS proposes to post the names of group practices that: (1) submit data on the 2011 PQRI quality measures through one of the proposed group practice reporting options; (2) meet the proposed criteria for satisfactory reporting under the respective group practice reporting option; and (3) qualify to earn a PQRI incentive payment for covered professional services furnished during the applicable 2011 PQRI reporting period.
CMS also discusses that it is not proposing that performance information be made publicly available at either the group practice or individual level as a condition of participation in the 2011 PQRI. The AMA agrees with and supports CMS’ determination in this regard.
CMS discusses that section 10331 of the ACA, however, requires that not later than January 1, 2013, and with respect to reporting periods that begin no earlier than January 1, 2012, CMS must implement a plan for making publicly available through Physician Compare, information on physician performance, including measures collected under the PQRI. CMS will expand the information that is publicly posted on the Physician Compare Web site in future years and will be further described in future rulemaking.

The AMA looks forward to providing input into the design of the Physician Compare Web site. It is important to promote physician engagement in quality improvement though such factors as accurate benchmarking and other beneficial functions. We also suggest a process by which a physician or group can review and update their demographic information. The AMA understands this was a major challenge when the CMS Hospital Compare Web site was initiated.
Further, public reporting of performance information, if not approached thoughtfully, can have unintentional adverse consequences for patients. For example, patient de-selection can occur for individuals at higher-risk for illness due to age, diagnosis, severity of illness, multiple co-morbidities, or economic and cultural characteristics that make them less adherent with established protocols. Further, health literacy may not be adequate to comprehend basic medical information. Programs must be designed so that appropriate and accurate information is available to patients to enable them to make educated decisions about their health care needs.
If done correctly, public reporting has the potential to help provide such appropriate and accurate information to patients. There remain, however, several critical issues that must be resolved before public reporting provisions can be implemented. There must be a method for ensuring that any publicly reported information is: (i) correctly attributed to those involved in the care; (ii) appropriately risk-adjusted; and, (iii) accurate, user-friendly, relevant and helpful to the consumer/patient. Moreover, as CMS has acknowledged, an important aspect of a quality reporting program is that physicians have the opportunity to review their data on reporting rates on PQRI quality measures. Physicians and other providers involved in the treatment of a patient must have the opportunity for prior review and comment and the right to appeal with regard to any data that is part of the public review process. Any such comments should also be included with any publicly reported data. This is necessary to give an accurate and complete picture of what is otherwise only a snapshot, and possibly skewed, view of the patient care provided by physicians and other professionals or providers involved in the patient’s care.

Other factors that must be considered as part of any initiative to make performance data available to the public are as follows:
•    To date, there has been no formal, rigorous evaluation of the PQRI to determine such factors as: its impact on quality of care, whether it allows for fair and meaningful comparison of performance among physicians, and whether the data on physician participation is valid and can be verified.
•    A detailed educational program for the public should be undertaken to explain the PQRI and openly address its limitations, including barriers to physician participation and the fact that quality measures used in the program take into account only a small fraction of all dimensions that explain overall physician performance.
•    CMS should provide physicians an opportunity to explain why they did not participate in the voluntary PQRI and detail any quality improvement initiatives in which the physician is participating. This information should be provided to the public by CMS. Many physicians are participating in health care quality improvement projects conducted by Medicare’s Quality Improvement Organizations, CMS’ Coverage with Evidence Development mandates, health plans and various other quality initiatives. Physicians should have an opportunity to highlight these quality improvement efforts.