Audiologists and speech-language pathologists (SLPs) in
private/group practices or university clinics that currently bill
Medicare Part B for services need to report one measure for one
Medicare beneficiary on a payable claim for 2013 services in order to avoid
penalties in 2015.
Penalties will be assessed by the National Provider
Identifier (NPI) of the individual rendering service under each practice's Tax
Identification Number/NPI. Therefore, if a clinician works in two different
private practices, the clinician must report a PQRS measure for a Medicare
patient in each practice in order to avoid the 1.5% penalty on his or her 2015
The Physician Quality Reporting System was
initiated as a volunteer, incentive-driven reporting system in 2007 and is
transitioning to a penalty program for non-participation. The Patient Protection
and Affordable Care Act (ACA) requires participation in PQRS for 2015 and
subsequent years by implementing negative payment adjustments on claims for
covered professional services submitted for rendering providers who have not met
reporting standards. The Centers for Medicare & Medicaid Services (CMS)
determined to implement the negative payment adjustment through participation in
prior years: The 2015 adjustment is based on 2013
participation; the 2016 adjustment is based on 2014 participation. In
the 2013 Medicare Physician Fee Schedule Final Rule, CMS determined that one
valid, successful reporting attempt would exempt providers from the 2015
penalty. The requirements for 2014 are more stringent, requiring for
claims-based reporting that at least three measures are reported for 50% of the
individual provider's Medicare caseload. Future penalties will be assess on paid
claims from Medicare.
Audiologists and SLPs can meet the 2013
participation requirement by submitting codes on Medicare Part B claims
specifically for PQRS. The functional outcome reporting requirements for all
Medicare Part B therapy services does not satisfy PQRS reporting requirements.
All PQRS submissions must be completed for date of service in calendar year 2013
on payable claims processed prior to February 28, 2014. This requirement only
applies to providers billing for Medicare Part B outpatient services.
For more information, please contact Lisa
Satterfield, ASHA's director of health care regulatory advocacy, at [email protected].