Registry-based Reporting Mechanism

50.2 – Registry-based Reporting Mechanism (Rev. 10, Issued: 07-27-12, Effective: 10-29-12, Implementation: 10-29-12) 15 Beginning with the 2010 eRx Incentive Program, individual eligible professionals and group practices Individual eligible professionals and group practices may choose to participate in the eRx Incentive Program via the registry-based reporting mechanism for all reporting periods except those 6-month reporting periods associated with a payment adjustment. Eligible professionals and group practices that choose to participate in the eRx Incentive Program via the registry-based reporting mechanism do not have to enroll or register to begin registry-based reporting of the eRx measure to CMS. However, to report eRx measure data via the registry-based reporting mechanism, an eligible professional or group practice must select a qualified clinical data registry and must enter into and maintain an appropriate legal arrangement with a qualified clinical data registry. Such arrangements should provide for the registry’s receipt of patient-specific data from the eligible professional and the registry’s disclosure of eRx measure results and numerator and denominator data on behalf of the eligible professional or group practice to CMS. An eligible professional or group practice choosing the registry-based reporting mechanism must submit information on the eRx measure to their selected registry in the form and manner and by the deadline specified by the registry. Thus the registry would act as a Health Insurance Portability and Accountability Act of 1996 (Pub. L.104-191) (HIPAA) Business Associate and agent of the eligible professional. Such agents are referred to as “data submission vendors.” The “data submission vendors” would have the requisite legal authority to provide information on eRx measure results and numerator and denominator data on the eRx measure on behalf of the eligible professional for the eRx. Only a registry that is qualified to submit Physician Quality Reporting System quality measures information to CMS on behalf of eligible professionals for the applicable program year is eligible to become a qualified registry for the purpose of submitting eRx measure information to CMS on behalf of eligible professionals or group practices. CMS qualifies registries for the Physician Quality Reporting System for each program year through a self-nomination process (see Chapter 1, §50.2). The list of qualified registries for a specific program year are made available on the CMS eRx Incentive Program website at http://www.cms.gov/ERXincentive. For a specific program year, this list usually is made available in the summer of that same year. For example, we anticipate the list of qualified registries for the 2010 eRx Incentive Program was anticipated to be made available in the summer of 2010. Please note that, for all 6-month reporting periods associated with a payment adjustment, only the claims-based reporting mechanism may be used for purposes of the eRx payment adjustment. For example, for purposes of the 6-month reporting period for the 2013 payment adjustment (i.e., January 1, 2012-June 30, 2012, only the claims-based reporting mechanism may be used for purposes of the 2013 eRx payment adjustment even though the registry-based reporting mechanism was finalized for use by eligible professionals for the 12-month reporting period for the 2013 payment adjustment (i.e., January 1, 2011 – December 31, 2011) and for purposes of the reporting period for the 2012 incentive (i.e., January 1, 2012-December 31, 2012). As such, to the extent an eligible professional intends to use a registry to submit eRx measure data for purposes of qualifying for the 16 2012 eRx payment incentive, the eligible professional would still need to submit eRx measure data on claims for services furnished between January 1, 2012 and June 30, 2012, in order to avoid the 2013 eRx payment adjustment.