SLPs Lag in Medicare Enrollment Medicare data reveal some startling—and promising—trends for communication sciences and disorders professionals. Bottom Line
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Bottom Line  |   November 01, 2015
SLPs Lag in Medicare Enrollment
Author Notes
  • Lisa Satterfield, MS, CCC-A, is director of ASHA health care regulatory advocacy. lsatterfield@asha.org
    Lisa Satterfield, MS, CCC-A, is director of ASHA health care regulatory advocacy. lsatterfield@asha.org×
Article Information
Practice Management / Bottom Line
Bottom Line   |   November 01, 2015
SLPs Lag in Medicare Enrollment
The ASHA Leader, November 2015, Vol. 20, 22-24. doi:10.1044/leader.BML.20112015.22
The ASHA Leader, November 2015, Vol. 20, 22-24. doi:10.1044/leader.BML.20112015.22
Newly released information about Medicare providers indicates that although audiologists have enrolled in large numbers, speech-language pathologists have not followed suit, with potential widespread implications for advocacy efforts and reimbursement.
The Centers for Medicare and Medicaid Services (CMS) recently began the public reporting of data—including Medicare enrollment and participation in Medicare’s Physician Quality Reporting System (PQRS)—for individual providers of outpatient services (Part B).
Using Medicare’s Physician Compare website, Medicare beneficiaries can locate health care professionals, including audiologists and SLPs, who are enrolled as Medicare providers. They can search the data by location, provider specialty or condition, and compare providers based on their education and PQRS participation. At this time, the information is based on data from 2013.
Audiologists
According to the website, 11,613 individual audiologists were enrolled as Medicare outpatient providers in 2013. This figure represents a substantial percentage of the profession, with an overall employment estimate by the Bureau of Labor and Statistics of 12,250. However, the Medicare enrollment data includes duplications, counting enrollments linked to multiple practice locations, so the figure likely includes duplicate entries for audiologists who work in multiple outpatient sites. The data also do not include audiologists employed by hospitals or other inpatient facilities.
The PQRS data (see graph) demonstrate growth in reporting by audiologists, who became eligible for PQRS participation in 2008. The figures represent the total participation rates for Medicare-enrolled audiologists who are eligible for PQRS.
The information on 2013 PQRS participation indicates that 41.7 percent of the successful audiologist participants—those who reported quality measures on 50 percent of their eligible Medicare patients—qualified for the last incentive payment issued in 2015, which totaled $81,000 distributed across the profession.
Incentive payments ended with reporting in 2013, when Medicare also began the transition from incentives for participation to penalties for non-participation.

Information indicates that 41.7 percent of the successful audiologist participants qualified for the last incentive payment issued in 2015, which totaled $81,000.

Speech-language pathologists
SLPs—the newest eligible providers, recognized by Medicare in 2009—have enrolled in Medicare and participated in quality reporting at much lower rates. The number of individual SLPs enrolled in Medicare is the lowest among non-physician professionals, barely reaching 1 percent of the total number enrolled professionals (see chart).
In addition, only 3 percent of the individual Medicare-enrolled SLPs participated in PQRS, in any way, in 2013. Compared to colleagues in audiology (46 percent), physical therapy (46 percent) and occupational therapy (23 percent), SLPs have substantial room for growth.
Broad implications
Medicare enrollment demonstrates the importance of speech, language and hearing services to Congress, policymakers and other health care professionals. In a data-driven age, CMS tracks performance of procedures by facility and provider type to determine who “owns” the service. For example, the high percentage of Medicare-enrolled audiologists and their growth in PQRS participation demonstrate to CMS and the American Medical Association that audiologists are the primary providers of hearing and balance services, and that audiologists are preparing for payment systems based on quality and outcomes.
Conversely, SLPs’ low participation in Medicare significantly diminishes their collective advocacy influence. These statistics can have far-reaching payment and policy implications, as Medicare policy often influences reimbursement policies across all payers.
Individual implications
To the individual SLP, 2016 Medicare enrollment may be essential, as CMS has proposed restricting SLPs’ ability to bill “incident to” physicians.
Under this proposal, only “ancillary” services—those provided by support staff, not skilled professionals—should be billed under the physician. In addition, the proposal requires the physician to be on site when the “incident to” service is performed.
Medicare laws and regulation require that:
  • All covered services provided to beneficiaries be billed to the Medicare program.

  • The provider of the service must be a Medicare-enrolled, skilled professional.

  • Safe and effective administration of the service requires the skills of the professional.

With current laws and the proposed change to “incident to” billing requirements, SLPs who have not enrolled might be limited to performing “incident to” services only if the ordering physician is in the clinic and if speech-language services are considered ancillary.
Lost in the transition?
This enrollment and PQRS participation information is significant for audiologists and SLPs as Medicare transitions from a fee-for-service payment system to one based on service quality and efficiency and patient outcomes. Today’s PQRS will evolve into the Merit-Based Incentive Payment System, which combines quality reporting and cost-effectiveness measures.
To participate in the new payment models, audiologists and SLPs must enroll as individual providers and track the quality and the outcomes of the services they provide. Failure to report or poor quality ratings could result in payment reductions of double-digit percentages in coming years.
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November 2015
Volume 20, Issue 11