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 claims.
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 firstname.lastname@example.org.