Penalties Possible in Medicare Quality Reporting Clinicians who report outcomes on fewer patients than their colleagues in 2015 will find their 2017 reimbursements cut. Bottom Line
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Bottom Line  |   October 01, 2014
Penalties Possible in Medicare Quality Reporting
Author Notes
  • Lisa Satterfield, MS, CCC-A, is ASHA director of health care regulatory advocacy. lsatterfield@asha.org
    Lisa Satterfield, MS, CCC-A, is ASHA director of health care regulatory advocacy. lsatterfield@asha.org×
Article Information
Practice Management / Regulatory, Legislative & Advocacy / Bottom Line
Bottom Line   |   October 01, 2014
Penalties Possible in Medicare Quality Reporting
The ASHA Leader, October 2014, Vol. 19, 24-25. doi:10.1044/leader.BML.19102014.24
The ASHA Leader, October 2014, Vol. 19, 24-25. doi:10.1044/leader.BML.19102014.24
A new Medicare proposal—anticipated to become a final rule—will place 2017 penalties on speech-language pathologists and audiologists whose quality and quantity of 2015 participation in the Physician Quality Reporting System is less than that of other clinicians.
The proposal requires SLPs and audiologists (and other providers) who provide Part B services to join the Value-Based Modifier program that already applies to physicians. The penalty would be in addition to the penalty already in place for nonparticipation in PQRS. If finalized, the penalty for nonphysician providers who provide Medicare Part B services—but do not participate in PQRS in 2015—climbs to a 6-percent reduction on all Medicare claims for 2017. (The penalty for physicians tops out at 9 percent.)
What is the Value-Based Modifier?
The Physician Quality Reporting System requires Medicare Part B providers to report outcomes based on a set of measures. All Medicare Part B providers must participate or take cuts in their future years’ reimbursement.
The VBM reflects two factors:
  • Quantity. The provider’s level of participation in PQRS, relative to other providers reporting the same quality measure.

  • Quality. Whether the provider complies with the measure.

The VBM adjustment in 2017 ranges from a 4 percent cut to a 4 percent bonus, depending on the provider’s relative participation in 2015. ASHA’s analysis, however, indicates that audiologists and SLPs would not qualify for bonuses, only the penalty or no adjustment.
How does the VBM affect SLPs and audiologists?
Audiologists and SLPs must report on the documentation or confirmation of medications in the patient’s chart for at least 50 percent of all eligible visits to meet the minimum PQRS requirements. To report this measure, providers indicate “yes, I documented medication use” or “no, I did not document medication use.”
  • Quantity. One SLP reports outcomes on 75 percent of eligible patients; a second SLP reports on 95 percent of eligible patients. The second SLP will have a higher VBM.

  • Quality. Two audiologists report outcomes on 70 percent of their eligible patients. One audiologist reports “yes” for all of the patients she reported. The second audiologist, however, reports “yes” for half and “no” for the other half of patients she reported. The first audiologist will receive a higher VBM.

How do I figure out my VBM?
The VBM is based on comparisons with all other providers—including physicians and nonphysician professionals—who must report the documentation of medications. Because the VBM is based on a relative participation rate, rather than on specific benchmarks, providers cannot know what their VBM—or future penalties—will be.
There are other PQRS penalties, right?
Yes. Any eligible provider who fails to meet the minimum PQRS reporting requirement in 2015 will be penalized 2 percent on 2017 Medicare claims.
A provider who doesn’t participate in PQRS—or who fails to meet the minimum reporting requirement—in 2015 would see 2017 Medicare reimbursement cut by the maximum 6 percent.
What is ASHA doing about this?
SLPs and audiologists will have to comply with the rule in 2015, but ASHA is working with the Centers for Medicare and Medicaid Services and other provider organizations on a two-part strategy for the future.
The first effort is to ensure audiologists and SLPs are appropriately recognized in any pay-for-performance system. CMS, Congress, and health policy researchers recommend moving away from fee-for-service to a value- and quality-based payment system. However, the approaches so far—including the value-based modifier—have been physician-oriented, concentrating on the efficiency of physicians for certain chronic conditions and hospital re-admission rates and tracking these outcomes through evaluation and management codes billed only by physicians. The Medicare-developed efficiency measures are not relevant to the practice of audiology or speech-language pathology. ASHA has recommended that CMS postpone implementation of the value-based modifier and work with stakeholders in the audiology, speech-language pathology and other rehabiliation communities to develop efficiency and cost measures that appropriately reflect the services provided.
The second approach is to use research and best practices to develop measures of quality and outcomes that are clinically meaningful for clinicians and informative for patients.
Audiology measures. The three audiology-specific measures in the original PQRS were dropped; now, audiologists report on referral to a physician for at least 50 percent of their Medicare patients who have dizziness and on documentation or confirmation of medications in the chart for at least 50 percent of Medicare patients.
Through collaboration with the Audiology Quality Consortium, ASHA has worked to develop meaningful PQRS measures for audiologists. The AQC is now testing the validity of six measures of best practices:
  • Identification of benign paroxysmal positional vertigo through positional testing.

  • Functional testing of patients with hearing loss for cochlear implant candidacy.

  • Administration of patient-reported functional communication assessments as part of the hearing test battery.

  • Identification and treatment of tinnitus.

  • Care coordination for cochleotoxicity monitoring.

  • Care coordination for vestibulotoxicity monitoring.

Once the proposed measures have been peer-reviewed and their internal validity evaluated, the AQC will submit them for endorsement by the National Quality Forum and for use in PQRS. The timeline for acceptance and adoption into PQRS is uncertain.
Speech-language pathology measures. SLPs have been able to quantify their patient outcomes through ASHA’s National Outcomes Measurement System since 1998, and in the early implementation of PQRS, eight of the NQF-endorsed functional communication measures for stroke patients were included in PQRS. However, NQF eliminated the functional communication measures from PQRS in 2013, leaving SLPs to report only on the documentation or confirmation of medications in the patient’s chart for at least 50 percent of all eligible visits.
Under 2014 Medicare rules, registries—including NOMS—could be used for PQRS as a Qualified Clinical Data Registry, which allows registries with non-PQRS measures to be used for PQRS and the value-based modifier program. ASHA is already planning to modify NOMS to comply with the data registry requirements.
What should clinicians do in the meantime?
  • Audiologists and SLPs in private practice, group practice, university clinics and critical access hospitals who provide services to original Medicare Part B beneficiaries must participate in PQRS in 2015—or lose Medicare income in 2017. Providers in other settings should learn what quality programs are being implemented.

  • Members who receive the surveys for measure validation should provide their input. Continue to watch for these opportunities from ASHA.

  • Keep watching The ASHA Leader for updates on PQRS and pay-for-performance.

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October 2014
Volume 19, Issue 10