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Bottom Line  |   April 2014
Bottom Line: 2014 PQRS Reporting How-Tos
Author Notes
  • Lisa Satterfield, MS, CCC-A
    is ASHA director of health care regulatory advocacy. ■lsatterfield@asha.org
Article Information
Practice Management / Bottom Line
Bottom Line   |   April 2014
Bottom Line: 2014 PQRS Reporting How-Tos
The ASHA Leader, April 2014, Vol. 19, 28-29. doi:10.1044/leader.BML.19042014.28
The ASHA Leader, April 2014, Vol. 19, 28-29. doi:10.1044/leader.BML.19042014.28
As the Medicare Physician Quality Reporting System continues its transition—from a volunteer, bonus-driven system to a penalty program for nonparticipation—the rules for compliance also change. Following some new clarifications from the Centers for Medicare and Medicaid Services, figure out if PQRS applies to you and how to avoid the penalties, which are reduced reimbursements in future years.
Q I work in a physician otolaryngology practice and don’t submit my own claims. Does PQRS apply to me?
Yes, it does. PQRS applies to all providers in private or group practices or university clinics that submit claims to Medicare Part B for outpatient services. PQRS does not apply to medical facilities—hospitals, skilled nursing facilities and university medical centers—that bill under a facility or institutional provider number.
Q I work in a group practice with other providers. If I don’t participate in PQRS, do we all get penalized?
No, not exactly. The payment reductions for PQRS are applied to future claims submitted by the practice, but only for the services by the nonparticipating provider. In other words, if one provider in the practice complies with the PQRS requirements, then 2016 claims listing that provider as the “rendering” provider (who performed the service) will be paid in full. When 2014 nonparticipating providers bill Medicare in 2016 for their services, Medicare will cut the reimbursement for those claims by 2 percent.
Q My office manager said that I am not a rendering provider; all claims are submitted through the physician. Do I have to participate in PQRS?
The answer depends on whether you are a speech-language pathologist or an audiologist.
If you are an audiologist, Medicare requires that claims for all hearing and balance services provided by an audiologist must indicate the audiologist as the rendering provider on the claim—so yes, you must participate in PQRS to avoid the future penalties.
If you are an SLP, Medicare allows claims through the physician, who is then responsible for PQRS participation.
Q Hold on—to be a rendering provider, do I need to enroll in Medicare?
Yes, you need to enroll. Audiologists and SLPs do not have an “opt-out” provision with Medicare—that is, SLPs and audiologists who provide services to Medicare Part B beneficiaries must enroll in and submit claims to Medicare. Federal law mandates this provision as protection for Medicare beneficiaries to ensure they do not pay privately for certain Medicare benefits.
Q To participate in PQRS, do I have to sign up?
No, there is no registration process. PQRS automatically applies to claim forms that list you as the rendering provider.
Q What do I need to do to avoid penalties?
You must report your actions on quality measures that are specific to your profession.
Audiologists must report on referral to a physician for at least 50 percent of their Medicare patients who have dizziness; they also need to report on documentation or confirmation of medications in the chart for at least 50 percent of Medicare patients.
SLPs must report on the documentation or confirmation of medications in the patient’s chart for at least 50 percent of all eligible visits.
Q How do I report the measures?
You report your “action” on the Medicare claim form for the eligible procedure using special “G” codes assigned to each “action.” Medicare collects the codes during claims processing and analyzes them at the end of the year to determine if you meet all of the requirements (see resource box for website with specific, step-by-step information).
Q I don’t collect medication information. What is an easy way to meet these requirements?
The only way to participate in PQRS and to avoid penalties is to document this information. You must:
  • Start collecting medication information from your patients. Request that they bring a list of the name, dosage, frequency and route (for example, oral or injection) to their appointment or treatment visit. Place the list in the patient’s chart.

  • Every time you see the patient, ask if the patient’s medications have changed, and document the answer.

  • Familiarize yourself with the PQRS codes, including the procedure codes that require reporting.

  • Add the PQRS codes to your superbill/billing documentation so that you can indicate quickly which code(s) you performed at the visit.

  • Attempt to fulfill the PQRS requirement at every eligible patient visit, even though the benchmark is 50 percent.

Q Are there other measures I can report?
Yes, but only the dizziness and medications for audiologists and medications for SLPs count toward “participation” and, therefore, avoiding future penalties. Audiologists also may screen for depression; SLPs may perform pain assessment.
Q I’m an SLP and I already indicate G-codes and severity modifiers to report functional outcomes on the claim. Does this count toward my PQRS participation?
No, it does not. The functional outcome reporting requirements for therapy services are completely separate from PQRS and do not meet the PQRS requirements.
Q How long is PQRS going to be around?
Policymakers continue to look to quality and outcome reporting as the basis for payment systems. It is likely that PQRS or similar programs will be around for the long haul, and that penalties and reporting expectations will continue to increase.

Still Confused?

For help getting started with PQRS, check out these ASHA resources.

  • “Maximize Medicare Payment with PQRS” (on.asha.org/pqrs-webinar) is a 0.2-CEU on-demand webinar available for purchase. It includes quick reference handouts for audiologists and SLPs.

  • The audiology webpage “Reporting Audiology Quality Measures: A Step-by-Step Guide” (on.asha.org/reportingaudquality) includes tables and flowcharts.

  • The speech-language pathology webpage “PQRS Measures for SLPs to Report on Claims” (on.asha.org/pqrs-for-slps) includes tables and flowcharts.

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April 2014
Volume 19, Issue 4