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Evaluating options for submitting QPP measures

There are five methods to submit clinical quality measures under the Physician Quality Reporting System (QPP):

  1. Claims
  2. Qualified Registry
  3. Data submission vendor (DSV)
  4. Qualified Clinical Data Registry
  5. EHR Direct

In choosing a QPP submission method, there are a number of factors to consider, including:

Cost. There are costs involved in each QPP submission method Qualified Clinical Data Registry, Claims, Registry and DSV  require the cost of these vendors to enable them to validate, compile and review your data and submit to CMS on your behalf.  EHR Direct involve costs associated with all _EHR upgrades and any options associated with QPP reporting.

Your EHR. In order to submit QPP measures via EHR Direct, you must have an EHR that is capable of submitting EHR-derived data direct to CMS, which is a challenge for many practices. There are only 24 EHR vendors that successfully tested for EHR Direct with CMS for 2013 QPP EHR Direct reporting. Eligible professionals (EPs) using an EHR not capable of EHR Direct reporting must submit quality measures through a DSV if they want to use an EHR-based reporting method. If you don't have an EHR or a vendor capable of EHR-based reporting, you must use the claims, registry or registry GPRO reporting options.

Risk of data integrity issues. Anytime you convert data from one system to another, you risk losing data integrity. Reporting through the registry-based or DSV that uses registry submission options introduces this risk of data integrity. Be sure to take this into consideration when choosing a submission method, keeping in mind that QPP will impact your future reimbursement through CMS' value-based modifier payment program and your portrayal in the public eye under the CMS' Physician Compare website.

Complexity of the submission process. Not all QPP reporting methods are created equal; some are much more complex and difficult than others. Of the five reporting options, claims-based and group practice reporting options are most complex. Be sure to consider the complexity of the submission method before choosing the one that is right for you.

Participation in other CMS initiatives. If you are participating or planning to participate in the Medicare EHR Incentive Program, you may want to participate in QPP via one of the EHR-based reporting methods (QCDR, EHR direct and DSV). CMS has aligned these programs, and providers can earn double credit for their data by participating in the QPP Medicare EHR Incentive Pilot.
 

 
   
   
   
   
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For more information, contact us via email at clientservices@cuhsm.org

Phone:  (888) 979-2499 x2

Universal Health System Metric Tools referenced on this site:
CMS Submission Toolkit, CST-CMS Submission Template, PQRS
Audit Tool, PQRS Validator, GPRO Aggregator,
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QCDR-HISP = Qualified Clinical Data Registry - Health Information Service Provider

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Last modified: Tuesday November 10, 2020.