Physician report cards must give correct grades
■ CMS must ensure that doctors' information is accurate before letting research groups publish Medicare billing data.
Posted Sept. 5, 2011.
Physicians are all for giving patients the best and most complete information about their medical options and letting them choose the doctors who are right for them. But if patients are given false choices based on faulty data, it's not just a wasted opportunity -- it's a recipe for genuine harm.
Following a mandate in the health system reform law, the Centers for Medicare & Medicaid Services unveiled a proposed rule in June that would allow certain research firms and other qualified organizations access to Medicare billing data to develop public quality report cards on physicians, hospitals and others. Because the federal data would be combined with claims information from private insurers, it is potentially the biggest single release of individual physicians' information to date, and it raises a host of worrisome issues for doctors.
The plan would direct the approved organizations to use claims data from the private sector and Medicare to compare physicians with one another on quality and efficiency standards. This is sensitive information, and the recipients of the claims will be trusted with a great responsibility.
That's why the American Medical Association and 81 other physician organizations sent comments on Aug. 8 to CMS listing several issues that need to be resolved in the final rule for performance reports to be effective. Organized medicine supports the concept of meaningful quality performance reports, but only with stringent safeguards to ensure that underlying physician data are valid and reliable.
CMS recognizes the need to allow physicians to fix errors before they become the basis of a faulty public report card. Under the proposal, for instance, qualified entities using data to develop performance reports would be required to share those reports with doctors at least 30 business days before public release. Doctors then would have at least 10 business days to request the underlying data and another 10 days to ask for an error correction.
But that narrow window doesn't allow adequate time for busy physician practices to review the information and lodge appeals if it is wrong. CMS must require qualified entities to provide reports to doctors at least 90 business days before making the results public. Doctors then should be given at least 10 days to request data and an additional 30 days to ask for corrections.
Requesting a correction also is no guarantee that the research entity will comply. That's why comments made by physicians on the accuracy of their own claims information during the review should be included along with any publicly reported data. This step is necessary to give patients a complete and accurate view of what otherwise might be an incorrect, misleading or outdated picture of the quality of care provided by certain doctors.
The final CMS rule also must standardize the process for developing performance reports and the data to be used, including requirements on the content and formatting of reports and appeal processes. The AMA is drafting standards for reporting physician data that, once finalized, could serve as a reference for creating apples-to-apples comparisons -- even between Medicare and private payer claims databases.
But ensuring information accuracy starts well before that -- when Medicare chooses which organizations will gain access to the data. Qualified research groups must demonstrate expertise and sustained experience in handling claims data before they should be given a passkey to Medicare's database. Once inside, qualified entities should receive only two previous years' worth of claims data for any physician instead of the proposed three years. That would ensure that the reports are based on more recent data and lessen the chances that report cards would paint a picture that is no longer accurate.
If these safeguards aren't put in place, patients who view inaccurate or misleading report cards would be at risk for more than just wasted time. They might make decisions not to see the doctors who -- despite what the quality assessments would seem to indicate -- would provide the best care for their particular situations. Patients deserve more certainty and better guidance than that.