Frequently Asked Questions About How Medicare's Claims-based Reporting Relates to NOMS
How is NOMS related to the outcome measurement requirements using G-codes?
The CMS requirement for all SLPs to report outcomes on the claim form is not the same as participating in NOMS data collection. The CMS outcome measures for claims-based reporting uses a G-code and accompanying severity/complexity modifier based on the NOMS Functional Communication Measures (FCMs). The modifier represents the functional impairment on a 7-point severity/complexity scale.
Do I need to be NOMS certified to report G-codes?
No. The Functional Communication Measures [PDF] related to the CMS rule are in the public domain and can be used in your documentation without participation in NOMS. The FCMs are a series of seven-point rating scales, ranging from a least functional (Level 1) to a most functional (Level 7). The FCMs are not dependent upon administration of any particular formal or informal assessment, but are clinical observations provided by the SLP of an individual's communication and/or swallowing ability.
While the FCMs are in the public domain, the NOMS Adult data collection tool and the training are not and are exclusively tied to participation in NOMS data collection. The NOMS training provides an overview of the data collection procedures to ensure the integrity of the data reported to ASHA.
Does CMS require participation in NOMS to report G-codes?
CMS does not specifically require NOMS participation and ASHA does not submit NOMS data to CMS for the claims-based outcome reporting requirement. However, because CMS used NOMS as a standard in the development of the G-codes and severity modifiers, NOMS is a natural resource for SLPs to track outcomes of their patients and assist SLPs with code and modifier selection and documentation.
ASHA is working on a number of enhancements to the NOMS data collection tool to assist our NOMS sites with claims-based reporting. NOMS enhancements will include:
- New G-Code converter. SLPs will automatically receive Medicare G Codes and severity modifiers corresponding to the FCM data they enter on admission, interim and discharge.
- New goal setting feature. SLPs will have access to real-time national benchmarking data based on patient characteristics (e.g. diagnosis, severity level) to assist with goal setting.
- Flexible data reporting. New interim reporting form will allow NOMS participants to collect data at Medicare-specified intervals, and not just on admission and discharge.
- Collection of new data points. NOMS will begin collecting data on SLP treatment goals.
Do I also need to participate in PQRS?
The claims-based reporting and the Physician Quality Reporting System (PQRS) programs are both managed by CMS, but they have separate and distinct requirements and relationships to NOMS. The data reported to one program do not translate to, nor are they shared with the other. PQRS is only for SLPs in private or group practice who bill directly to Medicare using their individual National Provider Identifier (NPI) and provide specific services to Medicare Part B beneficiaries that have been diagnosed with late effects of a stroke. For claims-based reporting using G-codes, CMS requires the outcome data to be submitted by the facility or provider with the claim for the service. For PQRS, ASHA's NOMS is an approved registry. As an approved registry, SLPs enter their data into the NOMS data collection system and ASHA submits data to CMS on their behalf.
How will participation in NOMS data collection help me?
ASHA has a strong interest in accruing national-level data for benchmarking and trend analysis across the healthcare continuum to help stakeholders make data driven decisions about prognosis and expected functional outcome of treatment for patients with a particular disorder or diagnosis. By participating in NOMS data collection, you are contributing data to support your practice, your organization, and the profession.
In exchange for submitting data to ASHA, your facility will have access to data reports profiling your organization against national data, and if applicable, system data. Facilities may also run customized analyses of their data, as well as national data, using our Web-based reporting system.
Where can I find more information?