Credit freeze hinders PQRS feedback, AOA offers guidance

December 1, 2016
AOA diligently working to help doctors, students following data breach.

Precautionary credit freezes could obstruct doctors' access to Physician Quality Reporting System (PQRS) feedback reports, the AOA warns, as fallout of a profession-wide data breach continues to dog optometry.

Earlier this fall, the Centers for Medicare & Medicaid Services (CMS) made available 2015 PQRS Feedback Reports to show whether doctors satisfactorily reported and if they were subject to a 2% payment penalty assessed on their upcoming 2017 Medicare Part B claims. These unsuccessful 2015 PQRS participants were notified via letter from CMS shortly after.

Given CMS' decision to markedly increase 2015 reporting measures, doctors were encouraged to immediately review these feedback reports and provide input to the AOA if they were assessed a 2017 payment penalty. However, prudent action on the part of doctors and students to place a freeze on their credit to hedge against an ongoing, unresolved wave of identity theft may inadvertently hinder this review process.  

The AOA confirmed that doctors who froze or blocked their credit cannot immediately access their 2015 feedback reports as CMS' Remote Identity Proofing (RIDP) process uses the credit reporting agency Experian to verify identities. When logging in to the CMS system, doctors are prompted to RIDP if not previously identity proofed.

This requires doctors to provide a set of core credentials, including:

  • Full legal name.
  • Social Security number (may be optional).
  • Birthdate.
  • Current residential address.
  • Personal phone number.

Experian then uses these credentials to locate an individual's personal information, and in some cases, may present individuals with questions based on their credit profile. This information is only used for identity proofing and does not affect credit scores, as Experian creates a "soft inquiry" that is only visible to the individual.

To continue CMS' RIDP process and access the feedback report, doctors must contact Experian's Consumer Assistance at 1.866.578.5409 to temporarily lift the credit freeze. Find Experian Consumer Assistance.

AOA assessing PQRS penalties

At the time, the AOA strongly advocated against 2015 PQRS requirements for doctors to report on nine measures for 50% of their applicable Medicare patients—a drastic increase from the three measures required just one year prior. The high threshold, the AOA argued, was inappropriate, considering these measures did not align to the patient care provided by doctors of optometry.  

The AOA already communicated to CMS our serious concerns regarding the 2015 PQRS requirements, as well as the fact that doctors, who dedicated time and resources to participating in PQRS, are being penalized in the same manner as those who chose to do nothing. CMS agreed to look more closely into the issues the AOA raised. If you would like to be included in this review, contact the AOA's Associate Director of Coding & Regulatory Policy, Kara Webb, at kcwebb@aoa.org.  

Data breach latest

This latest development in a months-long data breach is yet another headache for affected doctors and students and the AOA affirms its stance that optometry deserves to know the source of this breach. But until that point, the AOA will leave no stone unturned to ensure that doctors and students are protected and informed.

"This data breach has impacted doctors and students of optometry across the country, and we will continue to press for action, including federal investigation into the breach, to provide peace of mind for our members and colleagues," says AOA President Andrea P. Thau, O.D.  

Already, the AOA and affiliates effectively advocated for optometric testing organizations and state boards of optometry to immediately discontinue use of SSNs as personal identifiers, in favor of unique numbers wholly unrelated to SSNs or other sensitive personal information. Just weeks later, the National Board of Examiners in Optometry announced their implementation of OE Tracker Numbers to retire SSNs.  

So, too, the AOA continues its communication with federal law enforcement authorities, including last month's call on the U.S. Attorney General's Office for further Department of Justice investigation. 

"The AOA will continue to push for full accountability and advocate for our doctor and student members on this issue," said AOA Secretary-Treasurer Barbara L. Horn, O.D.

Learn more about AOA actions.

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