Meaningful Use Attestation Does Not Satisfy PQRS Requirements

Meaningful Use Attestation Does Not Satisfy PQRS Requirements

Lack of alignment in Meaningful Use and PQRS Confusing

There is some confusion in medical practices about whether Physician Quality Reporting System (PQRS) requirements are satisfied by attesting to Meaningful Use. I’ve heard from many practice managers that because they attested to the use of Clinical Quality Measures (CQM) through Meaningful Use, they’ve automatically fulfilled their requirements for PQRS reporting. This is simply not true.

PQRS and Meaningful Use are two separate incentive programs with their own sets of rules and requirements. Although both programs are administered by CMS, there is currently no alignment between the programs. Many EHR vendors recognize the administrative burden this creates and have made changes in their systems to accommodate reporting for both programs. But I urge you to take caution. In order to use your EHR for reporting PQRS data, it has to be tested, vetted and approved by CMS. So, even though your EHR may be certified for Meaningful Use, they must also be approved to participate in PQRS to satisfy the requirements of both programs.

Furthermore, approved EHR vendors fall into two categories based on the way they transmit data to CMS:

  1. Qualified Direct EHR Product – data is extracted directly from the EHR
  2. EHR Data Submission Vendor – acts like a registry by accumulating data in a separate area and sending that data to CMS

CMS has posted a list of qualified EHR vendors, including which type of data vendor they are. You can find that list on the CMS website. But, there’s one more caution, CMS approval of an EHR is version specific. So, while you may use an EHR that is on the approved list, you may have an older (and therefore not approved) version. You’ll have to upgrade to the new version if you want to take advantage of dual reporting.

PQRS is limited to reporting for 51 specific CQMs, so you must be certain that at least three of those measures are appropriate for your specialty for Meaningful Use reporting. Be careful when looking at the list of Clinical Quality Measures because the PQRS and NQS measure numbers and names are not the same. The current lack of alignment in the Meaningful Use and PQRS programs is confusing and costly for medical providers. CMS has recognized this and is working to bring them into closer alignment through a pilot program started with EHR vendors in 2012 and continuing into 2013. Until the programs are more streamlined, do your homework and fact-checking to be sure you are meeting the requirements of Meaningful Use and PQRS. While PQRS is an incentive program now, by 2015 the penalties for non-conformance will outweigh any incentives you may be eligible for today.

Listen to Rebecca’s two-part interview with Leslie Witkin of Physicians First, Inc. discussing the Physician Quality Reporting System (PQRS) on her radio program, MORE For Your Practice.

Download or listen to Part 1.

Download or listen to Part 2.

Rebecca Morehead (@rebeccamorehead) is a Practice Manager Strategist with over 20 years of experience in medical practice management, EMR implementation, MSO Business Management, Medical Billing and Meaningful Use Support. Morehead is helping Orlando-area medical practices to implement electronic medical record technology, complete security risk assessments of new and existing EMR technology, draft HIPAA security compliance manuals and many other workflow support services. She is the host of MORE For Your Practice radio show on, which offers Practice Managers solid ideas for navigating management of their busy medical practices. Tune in to MORE For Your Practice every Wednesday at 4:30 pm ET.