Medical Association, also confirmed the requests weren’t mandatory audits at all, despite sinister language in the letter threatening to report unwilling partici- pants to CMS “with potential further action, including recoupment” of physi- cians’ 2013 PQRS incentive payments. Organized medicine’s sleuthing led CMS to finally post a notice on its website,
tma.tips/MedicareNotice, in late March explaining the previously unheralded reviews (or “verification” process, as CMS describes it) and Arch Systems’ role in conducting them, and clarifying that they are not mandatory. According to the notice, the requests are going to select physicians “whose
data is inconsistent with norms … to provide CMS with information on the over- all rate of reporting error” and “identify measures or measure types for which reporting errors are most prevalent and the most common sources of those er- rors.” CMS also is similarly validating past data reported under the now-defunct e-prescribing incentive program. CMS did not respond to Texas Medicine’s repeated requests for comment. AMA officials say the reviews are part of a validation process CMS conducts
with all of its quality reporting programs for the purpose of ensuring and im- proving overall data accuracy. But this is the first time Medicare is conducting them for PQRS. AMA officials say CMS told them the reviews at this stage are not intended
to result in recoupment if reporting errors are found. At organized medicine’s request, CMS issued a set of frequently asked questions, tma.tips/CMSFAQs, removing references made in the letters to possible recoupment and instead stating that if Arch finds any errors in physicians’ records in the review process, the company will create a summary report of doctors’ overall compliance rate and provide CMS with a copy of the report.
FEAR FACTOR Unfortunately for Dr. Chesnut, the clock had started ticking to respond to the letter she had received. She’s glad her experience will help inform other doctors. “But I did this out of fear, because nobody, whether you’re a doctor or not,
wants to get anything in the mail implying an audit. The letter says it’s volun- tary, except if you don’t do it, they are going to tell CMS you didn’t cooperate and send you to Medicare jail or something,” she said. “Quality improvement is something I do anyway, not because I’m reporting to PQRS but because it’s the right thing to do for my patients. So it shouldn’t cost me more to prove it.” The letter Dr. Chesnut received calls the process a “measure validation.” But
“it’s basically an audit,” she says, describing the hours she spent culling charts, creating spreadsheets, and following instructions. According to Arch Systems, the company will begin conducting formal PQRS
audits next year. But CMS’ FAQs still refer to the voluntary reviews as audits, saying, “These audits are within the scope of CMS’ Medicare health care op- erations and health oversight activities, and Arch Systems will request only the minimum data necessary to carry out these functions.” CMS notes that “just because you [doctors] were selected for review for the 2013 PQRS and/or eRX, does not necessarily mean your results will be reviewed or audited in subse- quent program years.” If the current reviews are any indication of what’s to come, however, it’s not going to be pretty, according to Dr. Chesnut. A nurse reviewer contacted her to start a review of 30 random patient records
+ PQRS Measure Validation Process FAQs: tma.tips/CMSFAQs “Quality
improvement is something I do anyway, not because I’m reporting to PQRS but because it’s the right thing to do for my
patients. So it shouldn’t cost me more to prove it.”
July 2015 TEXAS MEDICINE 27
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