Options for Avoiding 2015 Medicare Payment Penalties

October 8, 2013

The Centers for Medicare & Medicaid Services (CMS) Physician Quality Reporting System (PQRS) requires minimal participation in 2013 in order for service providers to avoid a 1.5% penalty assessment on all claims submitted for Medicare Part B beneficiaries in 2015. There are three options for meeting participation requirements:

  • October 15, 2013, is the last day that audiologists and speech-language pathologists (SLPs) can register for the administrative claims-based reporting mechanism. This mechanism is designed for physicians using group measures. Because the group measures do not apply to audiologists or speech-language pathologists, registering for this option provides only a short-term qualification in 2013 for avoiding the 2015 penalty; it is not a method that ensures eligibility in future years.
  • February 28, 2014, is the deadline for audiologists and SLPs to submit claims via the claims-based reporting option [PDF] for Medicare Part B beneficiaries. One payable claim must be submitted and successfully paid with a qualifying PQRS g-code for services performed and rendered under an individual audiologist's or SLP's National Provider Identifier (NPI) number in 2013 in order for the service provider to avoid penalties in 2015.
  • Prior to the end of 2013, SLPs can avoid the penalties by participating in the registry reporting option [PDF] through the National Outcomes Measurement System. SLPs should allow adequate time for training, registration, and data collection. Utilizing NOMS for CMS function outcome reporting requirements does not constitute automatic participation for PQRS.


Reporting outcomes to Medicare and other payers is increasingly becoming a standard tied to payment. PQRS, first mandated in 2007, is transitioning from a volunteer, incentive-driven reporting system to a mandatory reporting requirement for all private and group practice providers submitting fee-for-service claims for services provided to Medicare Part B beneficiaries. In 2013, meeting benchmark requirements can result in a bonus payment of 0.5% on all Medicare Part B claims, but non-participation will result in a 1.5% penalty assessed on all claims submitted under a private or group practice and an individual rendering provider's NPI number for 2015. 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 and are expected to increase in subsequent years.

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For more information, please contact Lisa Satterfield, MS, CCC-A, ASHA's director of health care regulatory advocacy, at lsatterfield@asha.org.

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