Recently, the American College of Radiology (ACR) made significant progress in overcoming the nagging problem facing the radiology community as we transition from a volume- to a value-based healthcare system. At the core of the problem is the difficulty in establishing quality metrics for radiology that the broader medical community and CMS view as valuable. Without these metrics, radiologists are at a disadvantage when engaging in payment structures that reward value over volume.
College-run data registries—known collectively as the National Radiology Data Registry (NRDR)—are a vital piece of the college’s Imaging 3.0 campaign. The NRDR gained significant stature when it was approved recently by CMS as a Qualified Clinical Data Registry (QCDR).
The NRDR provides a portal for radiologists to submit diverse sets of quality metrics for benchmarking and serves as an umbrella for several more focused registries that collect disparate data, such as report turnaround times, nondiagnostic biopsy rates (liver, lung, and breast), CT radiation dose, IV contrast extravasation rates and, soon, lung cancer screening clinical and follow-up data, a condition of Medicare reimbursement for the recently approved program. Depending on the specific registry or metric, the data may be collected at the patient or exam level or aggregated to physician or facility level, helping benchmark anything from a process measure to a patient-care measure.
ACR maintains a total of five individual registries, and they have been around for some time, but participation has not been as robust as hoped given the serious national implications of the ability to measure quality. The QCDR status granted by CMS will be a game changer.
PQRS game changer
The QCDR is defined by CMS as an approved entity that collects clinical data for the purpose of patient and disease tracking to foster quality improvement in care. QCDR was created as an alternate way of satisfying the Physician Quality Reporting System (PQRS) requirements for Medicare providers. (PQRS is a CMS reporting program that uses a combination of incentive payments and payment adjustments to promote quality reporting by eligible professionals.)
QCDR adds to pre-existing mechanisms of satisfying PQRS requirements—from claims-based reporting of individual measures by individual physicians, to “measures groups” reported via a registry, to a group reporting mechanism that allows submission of specific measures via registry, web interface or via an EHR for an entire group practice.
Most of the pre-existing measures and mechanisms for PQRS compliance unfortunately had little relevance to the broader radiology community, providing a slim picking of measures deemed worthy of reporting. The QCDR status of NRDR will allow the radiology community to participate in PQRS with measures that make sense to radiologists and encourage quality care.
Reporting PQRS measures via the QCDR, and hence participating in the NRDR, does involve clearing a few hurdles. If a practice used the QCDR option, CMS is requiring data submissions at the patient exam level, slightly altering the previously existing data submission requirements of the NRDR. This requirement necessitates IT support for building a registry-compatible download from the reporting physician’s EHR when certain measures are chosen. Those in large health systems will likely have internal IT support; smaller practices may need to engage their EHR vendor.
CMS also has informed the public via the Medicare Physician Fee Schedule Final Rule for 2015 that PQRS measures, including those reported via the QCDR, will be made public on the government run website Physician Compare at Medicare.gov (although any QCDR measure not previously reported in other PQRS paradigms will have a one-year moratorium prior to being made public).
These hurdles may be worth tackling for yet another reason, given previous hints from CMS that claims-based reporting could be retired. The stakes of noncompliance also become greater as PQRS payment adjustments are phased in, and the new value modifier paradigm of payment is implemented by CMS.
Radiologists who wish to participate in the NRDR may be pleasantly surprised to learn that it provides a large, readily accessible pool of data for projects to satisfy the American Board of Radiology’s Practice Quality Improvement Part IV requirement under its Maintenance of Certification Program. (Use of the NRDR also satisfies a stage 2 Meaningful Use