Physical Therapy and PQRS in 2015: How to Report Successfully. Introduction. Learning Objectives American Physical Therapy Association 1

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1 Physical Therapy and PQRS in 2015: How to Report Successfully Heather L. Smith, PT, MPH reproduction or 1 Introduction Heather Smith currently serves as the Program Director of Quality for APTA. In her current roll, Heather coordinates quality initiatives for the Association and develops and implements key member resources related to quality. Two areas of focus in her work include the Physician Quality Reporting System (PQRS) and Functional Limitation Reporting (FLR)requirements for therapy services under Medicare. Heather previously worked the Quality Divisions for both New York Presbyterian Hospital and the Hospital of the University of Pennsylvania. Previous to her role in quality improvement, she was a practicing clinician for over ten years with the majority of her focus on orthopedics in the outpatient setting. reproduction or 2 Learning Objectives 1. Illustrate the purpose of the PQRS program and the relationship between reporting and payment. 2. Identify the quality measures for 2014 that apply to physical therapists in private practice settings. 3. Characterize the anatomy of a PQRS measure and the distinction between reporting the individual measures and measures groups. 4. Describe the successful reporting requirements for 2014 and identify common mistakes associated with unsuccessful reporting by physical therapists. 5. Determine the changes to practice operations you need to make in order to participate successfully in the PQRS program in Understand the basics of the new value based modifier program for American Physical Therapy Association 1

2 PQRS OVERVIEW reproduction or 4 What is your primary role (select one): clinician in private practice administrator in private practice other POLL 1 reproduction or 5 Is your practice currently participating in PQRS for the 2013 reporting year? yes, reporting 3 measures yes, reporting more than 3 measures no POLL 2 reproduction or American Physical Therapy Association 2

3 Current Quality Reporting Programs Under Medicare Healthcare Setting Quality Program(s) Mandatory Reporting Payment Incentive/ Penalty Inpatient (Acute Care Hospitals) IQR, Readmissions & VBP Yes Yes P4R & P4P in 2013 Long Term Care Hospitals (LTCH) Beginning in 2014 Yes Yes P4R Penalty 2% Inpatient Rehabilitation Facilities (IRF) Beginning in 2014 Yes Yes P4R Penalty 2% Skilled Nursing Facilities (SNF) MDS 3.0 Yes No Hospice Beginning in 2014 Yes Yes P4R Penalty2% Home Health OASIS, HH CAHPS Yes Yes P4R Penalty 2% Outpatient PQRS No, payment adjustments for non participation beginning in 2015 (based on 2013 data) Value based Modifier (VM) No tied to participation in PQRS Yes P4R Incentive 0.5% through 2014, Penalty 2.0% 2016 and beyond Yes P4P +4.0x to 4.0% +2.0x to 2.0% Functional 2014 Limitation American Physical Yes Therapy Condition of payment 7 Reporting (FLR) reproduction or PQRS in Evolution Updates annually in the Physician Fee Schedule Rule 2006 TRHCA 74 measures Claims based only 2007 MMSEA 119 measures 4 group measures Claims & registry 2008 MIPPA 153 measures 7 group measures Claims & registry EHR testing er 2010 ACA & HITECH 170 individual measures 14 group measures Claims, registry, & EHR erx GPRO 8 PQRS Eligible Providers In 2015, eligible providers who bill under the physician fee schedule must report successfully under PQRS to avoid a 2.0% reduction in their 2017 fee scheduled. Rehab agencies, outpatient hospitals, SNFs Part B unable to participate in PQRS; use UB 92 (UB 04) or 837I for billing to intermediary No place on claim form for individual NPI American Physical Therapy Association 3

4 Increasing PT/ OT Participation in PQRS redistribution prohibited % 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% PT/ OT PQRS Data Submission Mechanism Claims Individual Claims Group Registry Individual Registry Group 11 Recent PPS Survey on PQRS Response: 540 members 85.0% participating in PQRS in 2014 The top reason sited for non participation: practice does not have resources to manage the PQRS reporting burden; we are willing to take the 2.0% penalty to avoid the reporting burden (8.0%) 83.7% report via claims 76.5% have never accessed a feedback report Only 31.0% have received a bonus in past years American Physical Therapy Association 4

5 2014 Top Reported Measures for PTs # Measure Description Reporting % 128 Preventive Care and Screening: Body Mass Index (BMI) Screening 34.1% and Follow up 130 Documentation and Verification of Current Medications in the 45.7% Medical Record 131 Pain Assessment Prior to Initiation of Patient Treatment 65.7% 154 Falls: Risk Assessment 48.5% 155 Falls: Plan of Care 42.4% 182 Functional Outcome Assessment 55.7% Based on PPS survey results 13 PQRS Participation 2015 (Reporting Period January 1 December 31) Individual Professional GPRO (Group Practice Reporting Option) Data analyzed at the NPI level/tin level No registration required Data analyzed at the practice TIN level (Includes all NPIs in group) Registration required by June 30, 2015 Reporting mechanism: claims or registry Reporting must be done via registry 14 Medicare Quality Reporting and Payment Calendar/ Current Year (Data Year) Year Penalty/ Payment Applied PQRS Penalty* (calculated by NPI/TIN) VM Incentive/ Penalty** (calculated by TIN) Cumulative PQRS & VM Penalty % N/A 1.5% % N/A 2.0% % N/A 2.0% % Up to 4.0% Up to 6.0% * The PQRS penalty will apply to eligible PT s who do not report OR who fail to meet the successful reporting requirements for PQRS in a given calendar year **The VM full VM penalty will apply to eligible PT s who do not report OR who fail to meet the successful reporting requirements for PQRS in a given calendar year American Physical Therapy Association 5

6 2015 PQRS Payment Adjustment What if I did not participate in PQRS in 2013 or I failed to meet the reporting requirements for PQRS in 2013 Successfully reports 3 measures on 50% or more of eligible Medicare patients OR Reported at least one measure on one patient Providers will receive 98.5% of Medicare Part B PFS allowed charges amount (or 1.5% less reimbursement) for all charges with dates of service from January 1 December 31, The Financial Impact of PQRS Calendar/ Current Year (Data Year) Year Penalty/ Payment Applied PQRS Penalty (calculated by NPI/TIN) Estimated Loses per Therapist* % $ % $ % $ *Penalty dollar amounts based on the median total Medicare payment amount for physical therapists in 2012 $32, PQRS: Public Reporting & Future Providers who report successfully in the program will have their names listed on the CMS website CMS is planning to make: 2015 PQRS GPRO data to be available Physician Compare Website in CY2016 for all groups of 2 or more Eligible Professionals (EPs) individual EP PQRS data to be available Physician Compare Website in late CY2016 if technically feasible American Physical Therapy Association 6

7 PQRS REPORTING: GETTING STARTED reproduction or 19 How are you submitting your PQRS data to Medicare: via claims via registry POLL 3 reproduction or 20 Program Detail Successful reporting requirements Physician Fee Schedule: PQRS Changes in 2015 Changes Reporting of 9 measures (or 1 8 as applicable) on 50% of eligible patients will be needed to avoid the 2.0% penalty Requires reporting of 1 cross cutting measures Available measures Elimination of 245 Chronic Wound Care measure Elimination of Back Pain Measures Group New category of measure cross cutting Specific measure changes TBD (awaiting release of measure specification manuals) Future changes Strongly encouraging providers to move away from claims based reporting New Programs Value Based Modifier in CY2016 (penalty year 2018) American Physical Therapy Association 7

8 PQRS Participation 2015 Should I participate in PQRS in 2015? I want to avoid the 2.0% penalty in 2017 Report via claims Report via registry Report all available individual measures (128, 130, 131, 154, 155, 182) Select 9 individual measures (or if less available 1 8) 22 Successful Reporting in PQRS 2015 Individual Measures Claims Based OR Traditional Registry Reporting 12 Month Reporting Period (Jan 1 Dec 31, 2015) Report at least 9 measures covering at least 3 NQS domains, OR, if less than 9 measures covering at least 3 NQS domains apply to the eligible professional, report 1 8 measures covering 1 3 NQS domains*, AND report each measure for at least 50 percent of the Medicare Part B FFS patients seen during the reporting period to which the measure applies. Measures with a 0 percent performance rate would not be counted. Of the measures reported, if the eligible professional sees at least 1 Medicare patient in a face to face encounter the eligible professional would report on at least 1 measure contained in the proposed crosscutting measure set.** * For an eligible professional who reports fewer than 9 measures covering 3 NQS domains via the claims based reporting mechanism, the eligible professional will be subject to the MAV process, which would allow us to determine whether an eligible professional should have reported quality data codes for additional measures and/or covering additional NQS domains. **For those reporting via registry the successful reporting requirements are the same reporting as an individual professional or GPRO 23 Successful Reporting in PQRS 2015 Individual Measures Qualified Clinical Data Registry 12 Month Reporting Period (Jan 1 Dec 31, 2015) Report at least 9 measures covering at least 3 NQS domains AND report each measure for at least 50 percent of the eligible professional s applicable patients seen during the reporting period to which the measure applies. Measures with a 0 percent performance rate would not be counted. Of the measures reported via a qualified clinical data registry, the eligible professional must report on at least 1 outcome measure. Of these measures, the eligible professional would report on at least 2 outcome measures, OR, if 2 outcomes measures are not available, report on at least 1 outcome measures and at least 1 of the following types of measures resource use, patient experience of care, or efficiency/appropriate use American Physical Therapy Association 8

9 Measures Care Coordination Population Health Safety Effective Care Cross Cutting # Diabetes Foot Care #128 BMI Screening #130 Medication Documentation #131 Pain Assessment #154 Falls Screening #155 Falls Plan of Care #182 Functional Assessment # FOTO Measures Successful reporting requirements 9 measures in 3+ domains (if less 1 8 then 1 3 domains*) 1 required Totals *Subject to the MAV process 25 How Do I Choose a Reporting Method? Claims Registry Cost None Variable QDC Selection Each practitioner is responsible for Each practitioner is responsible for choosing and submitting the QDC s entering data into the registry Updating Reporting Requirements Timing of Data Submission Auditing Annual measure updates must be monitored by the facility Data must be submitted on +50% of all eligible Medicare patients Done on the initial submission of claim form Providers must obtain feedback reports from QualityNet and/or establish internal auditing process Registry monitors and incorporates annual measure updates Data must be submitted on +50% of all eligible Medicare patients Done throughout the year; ability to retrospectively submit data Registry provides participants with feedback reports throughout the year Initiatives Patient Assessment Instruments/PQRS/Registry Reporting.html 26 CMS Remarks on the Future of PQRS Claims based Reporting We understand that the claims based reporting mechanism remains the most popular reporting mechanism. However, to streamline the PQRS reporting options, as well as to encourage reporting options where eligible professionals are found to be more successful in reporting, it is our intention to eliminate the claims based reporting mechanism in future rulemaking. During this time, we encourage eligible professionals to use alternative reporting methods to become familiar with reporting mechanisms other than the claims based reporting mechanism American Physical Therapy Association 9

10 Physical Therapy Outcome Registry Timeline 2014 Testing and pilot launch 2016 & Beyond Continued PTOR growth 2015 Continued pilot testing and preparation for full launch in 2016 For further information please visit Or us at 28 PQRS MEASURES SPECIFICATIONS AND DETAILS reproduction or 29 Which of the following individual measures do you currently report (select all that apply): BMI screening (#128) Medications (#130) Pain assessment (#131) Falls measures (#154 & 155) Functional assessment (#182) POLL 4 reproduction or American Physical Therapy Association 10

11 Which of the following individual measures do you currently report (select all that apply): Diabetes measures (#126 & 127) Wound Care measures (#245) FOTO measures (# ) POLL 5 reproduction or 31 Do you report the back pain measures group? yes no POLL 6 reproduction or Individual Measures for PTs # Measure Description Claims Registry 126 Diabetes Mellitus: Diabetic Foot and Ankle Care, Peripheral Neuropathy: Neurological Evaluation 127 Diabetic Mellitus: Diabetic Foot and Ankle Care, Ulcer Prevention Evaluation of Footwear 128 Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow up 130 Documentation and Verification of Current Medications in the Medical Record 131 Pain Assessment Prior to Initiation of Patient Treatment 154 Falls: Risk Assessment 155 Falls: Plan of Care 182 Functional Outcome Assessment American Physical Therapy Association 11

12 2015 Individual Measures for PT s # Measure Description Claims Registry 217 Change in Risk Adjusted Functional Status for Patients with Knee Impairments 218 Change in Risk Adjusted Functional Status for Patients with Hip Impairments 219 Change in Risk Adjusted Functional Status for Patients with Lower Leg, Foot or Ankle Impairments 220 Change in Risk Adjusted Functional Status for Patients with Lumbar Spine Impairments 221 Change in Risk Adjusted Functional Status for Patients with Shoulder Impairments 222 Change in Risk Adjusted Functional Status for Patients with Elbow, Wrist, or Hand Impairments 223 Change in Risk Adjusted Functional Status for Patients with a Functional Deficit of the Neck, Cranium, Mandible, Thoracic Spine, Ribs, or other General Orthopedic Impairment 34 PT Measures and National Quality Strategy Domains Communication and care coordination Community / population health Falls plan of care (#155) Functional assessment (#182) FOTO measures (# ) BMI screening (#128) Pain assessment (#131) Efficiency and cost reduction N/A Safety Medication verification (#130) Falls risk (#154) Effective clinical care Diabetes measures (#126 &127) Person and caregivercentered experience and N/A outcomes Bolded measures are cross cutting measures 35 Measure Applicability Validation (MAV) Process Used when a clinician reports less than 9 measures Measures are grouped in clusters and if one measures is reported in the cluster all applicable measures in that cluster must be reported MAV is based on data submission (MAV process for claims and registry) Updated annually American Physical Therapy Association 12

13 MAV Process Example Initiatives Patient Assessment Instruments/PQRS/AnalysisAndPayment.html 37 PQRS Measure Specifications Published and updated annually Critically important to success Tells you everything you need to know about a measure Information Provided in the Specification: Measure description Instructions Denominator Numerator Rationale and Clinical recommendation statements 38 Who, When, What, and How of Reporting Reporting Clinical Importance Information Needed from Measure Specification Question Who Who counts? Denominator (patient age, eligible CPT codes*, ICD9 requirements if applicable) When What How When do I report? What do I need to include in my documentation? Which code do I report Instructions (reporting frequency) + denominator information Instructions (describe the relevant clinical actions that must be taken may need to refer to numerator definitions) Numerator (all available QDC s outlined in detail, including definitions for not eligible and reporting exceptions if applicable) * Most measures for PT s require reporting with the submission of CPT codes and 97002; see the measure specifications for details American Physical Therapy Association 13

14 Who, When, What and How Measure #130 Medication Documentation (2014) Reporting Question Who When What How Clinical Importance Who counts? When do I report? What do I need to include in my documentation? Which code do I report Information Needed form Measure Specification 18 years and older CPT codes: 97001, 97002, 97110, 97140, ICD9: N/A Each visit where any of the CPT codes are billed (97001, 97002, 97110, OR 97532) This measure is intended to determine whether or not documentation of a current medication list occurred for all patients aged 18 years and older. See Numerator for details. G8427 complete information G8430 not documented/ incomplete info G8428 not eligible 40 Reporting Details for Individual Claims Measures (2014) Measure Number Measure Description 128 Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow up 130 Documentation and Verification of Current Medications in the Medical Record 131 Pain Assessment Prior to Initiation of Patient Treatment Eligible CPT Codes for Reporting Frequency of Reporting Once per reporting period 97001, 97002, 97110, 97140, Each visit* 154 Falls: Risk Assessment 97001, 97002, Once per reporting period 155 Falls: Plan of Care 1100F AND 97001, 97002, Available Quality Data Codes G8417, G8418, G8419, G8420, G8421, G8422, G8938 G8427, G8428, G , 97002, Each visit* G8730, G8731, G8732, G8442, G8509, G F & 1100F, 3288F 1P & 1100F, 3288F 8P & 1100F, 1101F, 1101F 8P Once per reporting period 0518F, 0518F 1P, 0518F 8P 182 Functional Outcome Assessment 97001, Each visit* G8539, G8540, G8541, G8542, G8543, G8942, G9227 * Note that each visit is only reportable with the listed eligible CPT codes. 41 PQRS Quality Data Codes (QDC) QDC information is: Specific to each measure Updated annually (with measure review and revision) Specific to the clinical action taken by the provider American Physical Therapy Association 14

15 PQRS Quality Data Codes & Modifiers Do not use GP or K modifier with the QDC s CPT II Modifiers are allowed for the use in specific cases with the falls measures ( ) Exclusion Modifiers 1P: exclusion modifier due to medical reasons (e.g. not indicated due to absence of limb or already performed) Reporting modifier 8P: action not performed, reason not otherwise specified Credit for reporting, but no credit for performance Use judiciously! 43 PQRS FEEDBACK REPORTS reproduction or 44 Annual Feedback Report Timeline for 2015 Reporting Year February 28, 2015 Close of 2014 reporting period, last day to submit claims Summer 2015 Q interim dashboard released September/ October 2015 Release of 2014 annual feedback reports and bonuses Fall 2015 Q interim dashboard released Winter 2015 Q interim dashboard released Spring/ Summer 2014 data analysis of American Physical Therapy Association 15

16 How Do I Know if I am Successful? Therapist Measure # Billed Billed Billed Billed Billed Total Eligible Visits Total QDC s Submitted Reporting Rate Ann 128 BMI % 130 Medication % 131 Pain % Bob 128 BMI % 130 Medication % 131 Pain % BMI: once per reporting period when billing OR Medication: every visit when billing 97001, 97002, 97110, OR Pain: every visit when billing AND Reporting Success Yes NO 46 QualityNet Online Report Access 47 Annual Feedback Report Typically released 9 months after the close of the reporting period Annual provider feedback reports contain the following information: Roll up of the facilities performance (TIN level) Individual reports for each eligible provider in the practice (NPI level) Summary of reporting by measure Detailed report of measure errors American Physical Therapy Association 16

17 Interim Dashboard Report Interim dashboard reports contain the following information: Roll up of the facilities performance (TIN level) Individual reports for each eligible provider in the practice (NPI level) Raw data only 49 How Do I Utilize this Information Report Type and Frequency Information Provided Importance to Success TIN level report Annual Interim NPI level report Annual Interim NPI level error report Annual Overall success of the clinic and the individual practitioners Details the individual measures reported by a therapist and the reporting rates of those measures Details the individual reporting errors for each measure submitted by a therapist Managers can use this information to determine overall success of the clinic and the variation in reporting rates of the therapists Managers can use this information to determine the variation in reporting rates for each measure reported by a therapist Managers can use this information to determine the errors in data submission for each measure reported by a therapist 50 Performance Improvement and Feedback Performance Improvement Choose measures, Implement the select a reporting PQRS process in method, and your clinic educate staff Plan Do Adjust Check Make changes to Audit your your process as process, and your needed reporting performance Feedback Feedback on performance should be shared regularly with all staff involved in the process to increase your success Managers Clinicians Administrative staff Data transparency has been shown to increase performance reproduction or American Physical Therapy Association 17

18 PQRS REPORTING: CASE EAMPLE CLAIMS REPORTING reproduction or 52 PQRS Process: Claims Reporting Interim Quarterly Dashboard Reports for 2015 Final 2014 Feedback Report (released fall 2015) Source: CMS 53 Select the measure #131 Pain Assessment PQRS Step by Step: Individual Measures Review measure specifications Age 18+ years Determine when the measures should be reported Every visit CPT codes OR Perform and document all clinical actions Pain assessed through patient interview and a standardized tool Documentation of a follow up plan if pain present Determine the appropriate Quality Data Code (QDC) G8730 or other defined numerator Submit the selected QDC Submit via claims or registry American Physical Therapy Association 18

19 PQRS: Example 1500 Claim Form Functional limitation data with therapy modifier and severity modifier (GP & CK/CI) PQRS Quality Data Codes (QDC s) Functional limitation G codes are submitted with a $0.01 charge; CMS recommends that PQRS G codes are submitted with a $0.01 charge Both functional limitation and PQRS G codes are submitted with 1 unit attached 55 PQRS: RARC & CARC Remittance Advice Remark Code (RARC) for QDCs with $0.00 The new RARC code N620 is your indication that the PQRS codes were received into the CMS National Claims History (NCH) database. EPs who bill with $0.00 charge on a QDC line item will see N620 instead of N365. N620 reads: This procedure code is for quality reporting/informational purposes only. EPs who bill with a $0.00 charge on a QDC line item will receive an N620 code on the EOB and may or may not receive any Group Code or CARC. Claim Adjustment Reason Code (CARC) for QDCs with $0.01 The new CARC 246 with Group Code CO or PR and with RARC N572 indicates that this procedure is not payable unless non payable reporting codes and appropriate modifiers are submitted. In addition to N572, the remittance advice will show Claim Adjustment Reason Code (CARC) CO or PR 246 (This non payable code is for required reporting only). CARC 246 reads: This non payable code is for required reporting only. EPs who bill with a charge of $0.01 on a QDC item will receive CO 246 N572 on the EOB reproduction or 56 VALUE BASED MODIFIER (VM) PROGRAM: AN INTRODUCTION reproduction or American Physical Therapy Association 19

20 Prior to this call, have you heard about the value based modifier program? yes no POLL 6 reproduction or 58 What is the Value Based Modifier (VM) Program? VM was mandated by Section 3007 of the Affordable Care Act, to begin by This program is separate from PQRS. The VM is determined by using both cost and quality data to calculate payments. CMS will begin applying VM under the Medicare Physician Fee Schedule (MPFS) in CY2015 (using CY2013 data), beginning with physician groups over 100 providers. 59 Timeline for the VM Program 2015 (using 2013 data) VM program begins with MD groups over (using 2015 data) VM program expands to include all MDs 2016 (using 2014 data) VM program expands to MD groups (using 2016 data) VM program expands to include all nonphysicians including PTs American Physical Therapy Association 20

21 The Value Based Modifier (VM) and PTs CMS has finalized the inclusion of PTs in the VM program in CY2018, however this would be based on the PTs performance in CY2016. The VM program has a quality tiering methodology that takes into account both quality and cost. The quality portion of the methodology is based largely on PQRS performance. The cost portion of the methodology would not typically apply to PTs and PTs would be given an average rating on this section based on CMS guidelines. 61 Participants Physician groups over 100 providers* Physician groups over providers Physicians in groups 2 9 AND solo providers VM Program Expansion Non physician Eligible Professionals (EPs) in groups 2 9 AND solo providers Data Year VM Year Payment Adjustments % to +2.0x % to +2.0x % to +4.0x (MD groups 10+) 2% to +2x (MD groups up to 9 and solo providers) TBD: up to 4.0% *Group size determined by number of total eligible professionals who have reassigned payment to the practice in the calendar (reporting)year. 62 Estimated Impact of PQRS & VM for PTs in 2018 Based on 2016 Data Reporting Scenario PT practice successfully reports in PQRS PT practice does not report successfully PT practice chooses not to participate PQRS Penalty VM Incentive/ Penalty* 0% 0% to +2.0x to 4.0x based on group size (high quality performers may earn incentives ) 2% Additional penalty ( 2% to 4%) Total Impact in 2018* 0% to +2.0x to 4.0x based on group size Combined penalty up to 6% * Penalty estimates based on 2017 VM penalties. CMS will set 2018 VM penalties in the CY2016 rulemaking American Physical Therapy Association 21

22 Estimated Financial Impact of PQRS & VM in 2018 CY2016 Reporting Year Penalties PQRS VM Total ( 2%) (up to 4%) (up to 6%) Estimated Loses per Therapist in CY2018* $ $ $ *Penalty dollar amounts based on the median total Medicare payment amount for physical therapists in 2012 $32, KEYS TO SUCCESS FOR TODAY AND TOMORROW reproduction or 65 Keys to PQRS Success Decide on your reporting mechanism and your measures Individuals reporting via claims or registry GPRO reporting via registry Access and review your feedback reports Review feedback throughout the year Make practice changes as needed to improve your reporting performance American Physical Therapy Association 22

23 Keys to PQRS Success: Claims based Reporting Preparing for the 2015 reporting year Ensure that you have a reporting process in place Review the measure specification changes (check back for new APTA resources in December) Check your EOBs for RARCs/ CARCs and perform audits as needed throughout the year 67 Keys to Preparing for VM Program in CY2016 Preparing for the VM program in 2016 Actively participate and be successful in PQRS reporting in CY2015 Become knowledgeable in the basics of the VM program Check for VM updates with the release of the CY2016 Physician Fee Schedule rule 68 PQRS Resources APTA: Quality Resources CMS PQRS page Quality Net (general questions or feedback reports) (option #1, then #7) American Physical Therapy Association 23

24 VM Resources APTA: Quality Resources Coming soon CMS VM Program page Fee for Service Payment/PhysicianFeedbackProgram/ValueBased PaymentModifier.html 70 QUESTIONS If you have additional questions on PQRS or VM please feel free to contact us at ext 8511 OR If you are interested in participating in the Physical Therapy Outcomes Registry please us at reproduction or American Physical Therapy Association 24