We are hearing that many providers are receiving letters stating that they are being penalized for not meeting the requirements of PQRS even though they thought they were reporting correctly. These providers report that they have been using claim based reporting all year on all Medicare claims but are now told they do not qualify.
It seems that the PQRS reporting rules are more difficult, and in some cases even impossible, to follow. For example, we have several LCSWs who report on depression screening and elder abuse. They report on every Medicare patient they see so they are definitely over the 50% mark. However they only report on those two measures since those are the only two applicable ones for their situation.
They too received notice that they did not meet the PQRS reporting requirements. We contacted the PQRS help desk and we were advised that the codes used by the LCSWs, 90791, 90834 & 90837, are eligible for reporting 8 measures and that all 8 measures must be reported. One of the eight measures is body mass index. Most LCSWs are not qualified to discuss BMI with a patient since their BMI may be affected by other medical health issues and/or medications they may be taking for health issues and the LCSW would not be qualified to discuss that with the patient.
Another one of the eight measures is blood pressure. Again, LCSWs are not trained to take and/or monitor blood pressure on patients. Most patients who see LCSWs go there to discuss issues in their life, not to have the LCSW discuss their blood pressure, medications, or BMI. The only recourse is to file an informal appeal. We have done that on behalf of several providers stating that the requirements are not within their scope of practice. It is unfair that LCSWs are going to be penalized for not reporting on measurements that are not within their scope of practice.
The eight measures that must be reported by a LCSW are Body mass index, Hypertension, Alcohol, Tobacco, Pain Assessment, Medications, and Elder Abuse.
While most therapists are likely to discuss depression and possibly elder abuse we have to wonder what hypertension, body mass index, tobacco, etc have to do with the therapy for a patient who is suffering from anxiety. And how is a social worker going to assess the medication needs of a patient they are counseling for problems at work. And yet all eight screenings are required in order to meet the PQRS requirements. Does it make sense? We are closely watching to see how MACRA ends up working out.