DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for ...

CMS-1503-FC 1233
physicians excluded from the EHR Incentive Program to be able to participate in a
program that combines these two initiatives. For example, pathologists employed at
independent laboratories may be eligible for the EHR incentive but cannot participate in
the Physician Quality Reporting System because of the billing mechanism they use.
Response: While we appreciate the commenter’s interest in participating in both
the Physician Quality Reporting System and the EHR Incentive Program, we note that
these are two different, distinct programs. In addition, the term "eligible professional" is
defined differently under these programs. We understand that, as a consequence,
professionals may be eligible for one program but not the other. While we encourage
participation in both the Physician Quality Reporting System and the EHR Incentive
Program, we are not able to change the criteria for participation eligibility in each
program in order to accommodate professionals who would like to participate in both
programs, but do not meet the eligibility requirements for both.
Regarding the specific concern that pathologists who bill through independent
laboratories are unable to participate in the Physician Quality Reporting System,
independent laboratories are suppliers and do not fit into the Physician Quality Reporting
System definition of "eligible professional" under section 1848(k)(3)(B) of the Act.
Pathologists who bill directly to Medicare, however, are eligible to participate in the
Physician Quality Reporting System.
Comment: Many commenters expressed support for linking the Physician Quality
Reporting System with the EHR Incentive Program as it will reduce the burden and
variability of reporting and streamline administrative processes for health care providers
and for CMS and offered suggestions for us to consider as we develop our plan to