Reporting, Incentives, and Embracing the Tide of Change
By Sally Eggleston, MBA, RT(T)

Recently, the Senate Finance Committee and House Ways and Means Committee have requested input from stakeholders for a suggested Sustainable Growth Rate (SGR) overhaul. While we've been hearing about SGR reform for several years it does appear that the time may have come for us to really buckle down and address this issue. There's been a lot of talk surrounding bundled payments—which are likely inevitable in the near future—in addition to a heavy emphasis on value based performance (VBP). None of this should come as a surprise since we've been recently faced with other quality-focused programs such as the Physician Quality Reporting System (PQRS) and Meaningful Use.

Radiation oncologists are said to be specialists with one of the lowest participations, if not the lowest, in PQRS, but radiation oncologists who participate have received the highest incentive payments. The incentive period is over, and beginning in 2015, the program will apply a payment adjustment to eligible professionals (EPs) who do not satisfactorily report data on quality measures for covered professional services.

This doesn't mean that you have until 2015 before you see adjustments in payments, though. EPs who do not satisfactorily report data on quality measures for covered professional services during the 2013 PQRS program year will be paid 1.5 percent less than the Medicare Physician Fee Schedule (PFS) amount for services provided in 2015.

However, we have opportunities for incentives. For example, if an EP satisfactorily submits data on quality measures under PQRS for a 12-month reporting period in 2013 and meets the requirements of the Maintenance of Certification Program, he or she will receive a .05 percent additional incentive.

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Participation in PQRS by specialties has been difficult on numerous fronts, ranging from radiation oncologists typically not prescribing enough prescriptions to qualify for eRx and needing to file an exemption to choosing PQRS measures that can actually be met due to specific patient referral patterns.

One particular concern is the meaningful use of certified Electronic Health Record (EHR) technology. Physicians who practice in a hospital outpatient environment are particularly vulnerable when trying to meet this criterion. The Centers for Medicare and Medicaid Services (CMS) does exempt physicians who are hospital-based. While most radiation oncologists providing services in a hospital outpatient department consider themselves "hospital-based", CMS considers providers hospital-based if they provide more than 90 percent of their covered professional services in either an inpatient (Place of Service 21) or emergency department (Place of Service 23) of a hospital. So it's obvious that an exemption for being hospital-based is not going to work. Radiation oncologists practicing in hospital outpatient departments do not own, solely operate or, in some instances, have the ability to access the information from the EHR that they need for successful reporting. There have been instances of physicians being told that the hospital could not assist them in the professional reporting of Meaningful Use because it would be a Stark violation. To date, there doesn't appear to be an exemption for physicians in this predicament, but we hope that there's one on the horizon.

Ultimately physicians must recognize that the payment system we have known is quickly dissolving. While no one likes change, it is upon us and must be embraced. Participation in value-based quality initiatives is a must for receiving the full potential of CMS payments, whether fee for service or bundled. It will be essential to discuss with oncology specialty societies any potential concerns that may prevent our specialty from succeeding in all forms of value or quality reporting. It is vital that we embrace these value based components of "practice management”. Ignoring it and "just practicing medicine will prove to be costly.

RC Billing provides complete oncology billing services to complement your practice and assist you well into the future. For more information, contact us at or call 512.583.2000.


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