Policy Analysis: Medicare Providers: Report Once in 2013 to Avoid Future Penalties Feds clarify rules for required 2013 participation in the Physician Quality Reporting System. Policy Analysis
Policy Analysis  |   June 01, 2013
Policy Analysis: Medicare Providers: Report Once in 2013 to Avoid Future Penalties
Author Notes
  • Lisa Satterfield, MS, CCC-A is ASHA director of health care regulatory advocacy.
Article Information
Regulatory, Legislative & Advocacy / Policy Analysis
Policy Analysis   |   June 01, 2013
Policy Analysis: Medicare Providers: Report Once in 2013 to Avoid Future Penalties
The ASHA Leader, June 2013, Vol. 18, 16-17. doi:10.1044/leader.PA.18062013.16
The ASHA Leader, June 2013, Vol. 18, 16-17. doi:10.1044/leader.PA.18062013.16
Medicare providers need only report one valid measure on one eligible patient on one payable claim to satisfy the requirement to participate in the Physician Quality Reporting System in 2013. With this single report, eligible providers avoid a 1.5 percent reduction in their 2015 Medicare reimbursement levels.
The Centers for Medicare and Medicaid Services clarified this requirement in a March national provider call, stating that the single claim must include the provider's individual National Provider Identifier and the reported code.
Eligible providers include audiologists and speech-language pathologists in private or group practice who provide services to Medicare Part B patients, including providers in noninstitutional clinical settings—not a hospital or skilled nursing facility—that submit a CMS-1500 claim form for payment.
Implemented as a voluntary, incentive-driven system to track the quality of care and outcomes of Medicare beneficiaries with specific diagnoses, PQRS changes to a penalty-driven system in 2015. CMS rules indicate that all Medicare providers, including SLPs and audiologists, who fail to report on eligible beneficiaries in 2013 will be subject to a 1.5 percent payment reduction in 2015 and increased reductions in subsequent years. The reporting must be included in claims for services provided in 2013 and must be submitted by Feb. 28, 2014.
Discipline-specific reporting. To participate in PQRS, audiologists and SLPs may choose to report outcomes specific to their discipline or on a general practice measure related to medication. The audiology-specific measures are referrals to otologists for congenital or traumatic ear deformity and for dizziness. The speech-language reports—functional communication measures for stroke patients treated for spoken language comprehension, spoken language expression, motor speech, reading, writing, attention, memory or swallowing—are reported through a CMS-approved registry such as the National Outcome Measurement System.
Medication reporting for all disciplines. An alternative may be the medication-related measure, which can be reported on the claim form for CPT (Current Procedural Terminology, © American Medical Association) code 92557, the comprehensive audiology evaluation, and 92507, treatment of speech, language, voice, communication and/or auditory processing. Almost every audiology and speech-language patient, therefore, is eligible for reporting on this measure.
The claim must include a billable service. If the claim is denied for payment, the PQRS reporting is not captured in the system.
Dan Green, a CMS medical consultant, encourages all providers to consider reporting the medication documentation measure. He indicates that it is reasonable for any practitioner to ask about a patient's medications, even if the practitioner cannot prescribe medication. To report this measure, the provider should document the medication name, dosage, frequency and route in the medical record. Green also encourages providers to report on each eligible patient, stressing that it is better to over-report than to miss reporting opportunities.
A code (N365) on the Remittance Advice or Explanation of Benefits from Medicare will indicate that the PQRS code was received into the National Claims History file. The code states, "This procedure code is not payable. It is for reporting/information purposes only."
SLPs should note that participation in PQRS is in addition to the 2013 requirement that SLPs who provide services to Medicare Part B fee-for-service patients in all settings must report on patient progress and outcomes using nonpayable, program-specific G-codes on claim forms. This requirement is part of CMS efforts to collect data that may be used to create a new Medicare reimbursement system for therapy services. CMS will reject claims that do not include the required information. Reporting in the mandatory claims-based outcome reporting does not exempt SLPs from PQRS participation.
ASHA has step-by-step PQRS reporting instructions for SLPs and for audiologists.
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June 2013
Volume 18, Issue 6