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 Centers for Medicare and Medicaid Services (CMS) requirement that all SLPs treating Med B patients submit outcomes data with the claim for the service is not the same as participating in NOMS data collection. CMS adopted a series of outcome measures known as "G-codes" with accompanying severity/complexity modifiers for claims-based reporting. The CMS measures are based on the NOMS scales—ASHA's Functional Communication Measures (FCMs)—a series of seven-point rating scales ranging from a least functional (Level 1) to a most functional (Level 7). As such, NOMS and its FCMs can easily be used to report and track outcomes of Medicare patients.
Does CMS require participation in NOMS to report G-codes?
No. 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. The NOMS Web-based data collection instrument has a built in G-code converter that automatically generates the appropriate G-code and severity modifier based on the FCM score.
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 like CMS 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.
Can I use the NOMS scales without participating in data collection?
Yes. Eight of the 15 NOMS FCMs [PDF] are in the public domain. These measures can be used freely in your documentation without participation in NOMS data collection. While some of the NOMS FCMs are in the public domain, the NOMS Adult data collection tool, the additional 7 FCMs and the training are not and are tied exclusively to participation in data collection.
Do I need to complete a NOMS training to report G-codes?
No. The NOMS FCMs [PDF] 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. There is a NOMS training, but it is for data collection sites only. The training provides an overview of data collection and reporting procedures to ensure the integrity of the data submitted to ASHA by participating organizations.
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 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. View frequently asked questions related to PQRS.
Where can I find more information?