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Electronic Reporting Using an Electronic Health Record (EHR)

Individual EPs and group practices participating under the PQRS Group Practice Reporting Option (GPRO), referred to as PQRS group practices, may avoid the Physician Quality Reporting System (PQRS) negative payment adjustment by reporting electronically using an Electronic Health Record (EHR). Since 2014, CMS has discontinued the PQRS qualification requirement for data submission vendors and direct EHR vendors. To align with the Medicare EHR Incentive Program, EHR systems will instead need to be considered certified EHR technology (CEHRT). The Office of the National Coordinator for Health Information Technology (ONC) certification process has established standards and other criteria for structured data that EHRs must use. Also, since 2014, the electronic clinical quality measures (eCQM) specifications can be used for multiple programs, including PQRS, and the Medicare EHR Incentive Program to reduce the burden on providers participating in multiple quality programs. For 2015 reporting, EPs must report at least 9 measures covering a minimum of 3 National Quality Strategy (NQS) domains.

Individual EPs and PQRS group practices have the following CEHRT-based reporting options:

  1. Submit PQRS quality measure data directly from the CEHRT or
  2. Submit PQRS quality measure data extracted from their CEHRT to a qualified EHR data submission vendor (DSV) who submits on behalf of the EP or PQRS group practice.

Direct CEHRT Reporting

To submit quality measure data directly from an EHR, individual EPs and PQRS group practices need to verify that their direct EHR vendor is using CEHRT.

Individual EPs and PQRS group practices must also register for an Individuals Authorized Access to CMS Computer Services account (IACS). More information on registering for an account can be found at the Physician and Other Health Care Professionals Quality Reporting Portal (Portal).

CEHRT Reporting Through a Data Submission Vendor (DSV)

An EHR DSV is an entity that collects clinical quality data directly from the EP’s or PQRS group practice’s CEHRT. DSVs are responsible for submitting PQRS measures data from an individual EP’s or PQRS group practice’s CEHRT to CMS via a CMS specified format(s) on behalf of the EP or the PQRS group practice for the program year.

PQRS and the Medicare EHR Incentive Program

Individual EPs and PQRS group practices, who are also eligible for the Medicare EHR Incentive Program, have the opportunity to submit their CQMs electronically through the PQRS EHR reporting option to fulfill the CQM requirements for both PQRS and the Medicare EHR Incentive Program. EPs and PQRS group practices may satisfactorily report 12 months of CQM data to meet the reporting requirement for both PQRS and the Medicare EHR Incentive Program. Please note that the CQM reporting is only one component of the Medicare EHR Incentive Program; EPs and PQRS group practices must still meet the additional components of the Medicare EHR Incentive Program. For additional information on EHR Reporting Options, please visit the 2015 CQM Reporting Options webpage.

DSVs, individual EPs and PQRS group practices utilizing the direct EHR submission option, are able to submit data electronically to CMS. Regardless of the reporting period, data submitted on behalf of EPs or PQRS group practices must  be submitted via the Physician and Other Health Care Professionals Quality Reporting Portal (Portal) using an IACS account.

IMPORTANT: Individual EPs and PQRS group practices reporting electronically are required to use the July 2014 version of the eCQMs for 2015 reporting. To view more information, click on this direct link to the Medicare EHR Incentive Program’s eCQM Library.

2015 PQRS

2015 PQRS EHR Reporting Made Simple

2015 PQRS EHR Reporting Made Simple is a beginner-level document that outlines electronic reporting using an EHR for 2015 PQRS. It applies to individual EPs who wish to report using an EHR and PQRS group practices that registered to report via GPRO using an EHR.