Medicare is proposing sweeping changes to its Physician Quality Report System (PQRS) as part of its annual rulemaking process. Included in the FY 2014 Medicare Fee Schedule proposed rule are changes to the PQRS criteria that will adversely impact physician anesthesiologists. ASA is urging all members to submit comments to CMS regarding these changes.




Many ASA members use the “claims-based” method of reporting PQRS measures since it permits successful reporting when there are fewer than three measures applicable to an eligible professional (EP). At present, the Centers for Medicare and Medicaid Services (CMS) has criteria in place for physician anesthesiologists to successfully report quality measures; however, the proposed rule for the 2014 Medicare Physician Fee Schedule seeks to alter the criteria in a way that will place physician anesthesiologists at a great disadvantage.


CMS is moving toward elimination of the claims-based reporting mechanism and is seeking comment as to whether that mechanism should be eliminated in 2017. Some of the actions described in the proposed rule would sharply curtail claims-based reporting even sooner. Specifically, of the more than 40 proposed new measures CMS intends to add to the 2014 PQRS, none allow reporting via claims.


Additionally, CMS proposes to increase the required number of measures that must be reported from the current three (3) measures to nine (9). These nine measures must cover at least three of the National Quality Strategy (NQS) domains: Patient and Family Engagement; Patient Safety; Care Coordination; Population and Public Health; Efficient Use of Healthcare Resources; and Clinical Processes/Effectiveness.


Currently, there are a maximum of three measures applicable to most physician anesthesiologists. They all are within a single domain. Accordingly, if Medicare’s proposed rule is finalized, anesthesiologists will be unable to satisfactorily meet reporting requirements.


This change would have a significant impact on anesthesiologist’s practice because 2014 is the performance period for your 2014 PQRS incentive and for the 2016 PQRS penalty adjustment.


ASA will submit formal comments regarding these issues directly to CMS. Please make your individual voice heard, as well.




Please follow the below steps to submit a comment to CMS by September 6. This submission process will include completing a government online form with your first name, last name, city, country, state, zip code, organization name, category, and then using the copy & paste feature to place comments into the comment box. Problems should be directed to Please follow these below instructions step-by-step.


1) Click!submitComment;D=CMS-2013-0155-0010 to guide you to the comment submission area for this rule (Medicare Programs: Revisions to Payment Policies under the Physician Fee Schedule, Clinical Laboratory Fee Schedule and Other Revisions to Part B for CY 2014).


2) In the fields provided, please enter your first name, last name, city, state, zipcode, country (United States), and email address.


3) In the “Organization Name” field, please enter your state society of anesthesiologists (Eg., Missouri Society of Anesthesiologists).


4) In the “category” field, please select the option, ‘Physician—HC005’.


5) With your mouse, highlight the text below. Then copy and paste it into the “Comment Box”:


Marilyn B. Tavenner


Centers for Medicare & Medicaid Services

Department of Health and Human Services

Attention: CMS-1600-P

P.O. Box 8016

Baltimore, MD 21244-8016


RE: Medicare Program: Revisions to the Payment Policies under the Physician Fee Schedule, Clinical Laboratory Fee Schedule & Other Revisions to Part B for CY2014; Proposed Rule



Dear Administrator Tavenner:


As a physician anesthesiologist, I write to express concerns about changes the Centers for Medicare & Medicaid Services (CMS) is proposing for the Physician Quality Reporting System (PQRS) which will impact CY2014 and beyond.  


I strongly urge CMS to reconsider its stance on proposals that would currently weaken and ultimately eliminate the claims-based reporting mechanism. CMS acknowledges that a significant majority of PQRS Eligible Professionals (EP) use this method to report their quality measures; removing that option will be in direct conflict with efforts to increase participation in the PQRS program.


I write also about CMS’s proposal to increase the number of measures required to earn the 2014 PQRS incentive.   Increasing the minimum number of measures from three to nine with the additional stipulation that the measures cover three National Quality Strategy domains raises the bar higher than many specialties, including anesthesiology, can presently meet. CMS must achieve balance between its desire and directive to expand the PQRS program with the process and time it takes for 

specialties and other measure stewards to develop meaningful measures. CMS must also remain cognizant of the difficulties many specialties have encountered when proposing new measures for inclusion in the program.


In summary, I am asking that CMS:

  • Maintain the claims-based reporting option until all physicians are able to consistently, meaningfully, and accurately capture quality measures using Electronic Health Records (EHRs) or registries.
  • Not raise the minimum required number of measures above the maximum number of measures applicable to a specialty.



(Your Name)


6) Once you have cut and pasted the above language into the comment box, click “Continue” in the bottom right hand corner.


7) This will bring you to a preview of the letter you are about to send. Once you are happy with the contents, check the box at the bottom labeled “I Read and Understand the Statement Above” and click “Submit Comment”. This will send your comment to CMS and receipt of your comment will appear after sending.


Please submit your comments before 5:00pm ET on Friday, September 6, 2013!


For more information please contact Maureen Amos, M.S., Director of Quality and Regulatory Affairs or Sharon Merrick, M.S., CCS-P, Director of Practice Management at 202-289-2222.