With the Physician Quality Reporting System (PQRS) making the transition from the carrot to the stick, there's no time like the present for audiologists to start participating, said experts interviewed for this article.
“Participation had been incredibly low until last year, but when we started sending out messages about the upcoming payment reductions, we had more and more questions coming into the national office because nobody wants to be penalized,” said Lisa Satterfield, MS, director of health care regulatory advocacy for the American Speech–Language–Hearing Association (ASHA).
The Centers for Medicare & Medicaid Services (CMS) program used incentive payments for its first several years to promote the reporting of quality information by certain healthcare providers, called eligible professionals, or EPs.
Beginning in 2010, the first year audiologists were eligible to participate, the incentive payment was equal to two percent of providers’ total allowed charges for covered Medicare Part B Physician Fee Schedule (PFS) services. By 2014, the incentive payment had dropped to 0.5 percent.
The carrot now has been nibbled down to nothing and replaced with the stick. All EPs must report their PQRS data for 2014 or face a penalty of two percent on their Medicare Part B fees in 2016. The penalty for those who did not successfully report last year is 1.5 percent, applied in 2015.
Still, there's some good news for audiology.
“I think PQRS is a lot easier than people think it is—for audiologists, especially,” Ms. Satterfield said.
THREE AUDIOLOGY MEASURES
Under the 2014 Physician Quality Reporting System, three measures apply to audiologists:
- #261: Referral for an otologic evaluation for patients with acute or chronic dizziness. This measure should be reported once per year per relevant patient.
- #130: Documentation and verification of current medications in the medical record. This measure should be reported for every patient visit.
- #134: Screening for clinical depression and follow-up plan. This measure only applies to audiologists who already incorporate depression screening as a regular part of their practice (under their state's scope of practice) and is widely expected to be phased out.
There is no penalty for non-reporting of measure #134, said Debbie Abel, AuD, senior specialist in practice management for the American Academy of Audiology (AAA).
“But if you report on #261, you must also report on #130—they are linked together in an audiology cluster,” she said.
Previous iterations of the PQRS have used other audiology measures that have since been retired, including #188 for otologic referral of patients with congenital or traumatic deformity of the ear, and #189 for otologic referral of patients with a recent history of active drainage from the ear.
“When the system first came out, all the audiology codes were tied to referrals, and now they're trying to get away from referral measures and move to outcomes,” said Alicia Spoor, AuD, a Maryland audiologist who serves on the Academy of Doctors of Audiology (ADA)’s Board of Directors and on the Audiology Quality Consortium's committee.
THREE STEPS TO PARTICIPATION
In order to participate in the Physician Quality Reporting System, an audiologist must be a Medicare Part B provider, with a National Provider Identifier (NPI) and a Provider Transaction Access Number (PTAN).
“If you're in a group practice within a physician's office, the services you provide need to be billed under your own NPI number as the rendering provider,” Ms. Satterfield said.
Then, there really are just three steps to participation, Dr. Spoor said.
First, review the codes for each of the three eligible measures, using ICD (International Classification of Diseases)-9 (and, beginning in October 2015, ICD-10) and CPT (Current Procedural Terminology) codes to find eligible patients.
The Audiology Quality Consortium (AQC), a group of 10 audiology organizations that includes ASHA, AAA, and ADA, is working together with CMS to develop audiology-related PQRS measures.
The consortium educates providers on PQRS requirements and offers an online, step-by-step guide http://audiologist.org/_resources/documents/professionals/pqri/PQRS_Reporting_Audiology_Quality_Measures_2014.pdf that lays out exactly which ICD-9 and CPT codes are involved with each measure.
“The 2014 version of the AQC step-by-step guide literally sits right next to my computer,” Dr. Spoor said.
“When I bill, I take a quick glance at it—it's an extra 30 seconds when I put in my billing codes. And it's not something that's going to change often.
“For 2014, the information required is finalized, and, once I know it by heart, I don't even need the reference.”
G-codes are used to report the provider's actions. For the medication documentation measure, for example, there are three options:
- G8427, if the provider has documented a list of current medications, including drug name, dosage, frequency, and route, for prescription and over-the-counter medicines; herbals; and vitamin, mineral, and dietary supplements.
- G8430, if the provider documents that the patient is ineligible for medication assessment.
- G8428, if medications are not documented for an unspecified reason.
Second, fill out the CMS-1500 claim form using the proper coding.
Third, make sure CMS's minimum reporting requirements are met. This generally means reporting on at least nine quality measures for at least 50 percent of eligible patient visits.
Since audiologists do not have nine applicable quality measures, CMS permits reporting on just those measures that do apply, again for at least 50 percent of eligible patient visits.
The importance of referring patients with acute or chronic dizziness for physician evaluation is obvious to most audiologists, but the medication measure makes some clinicians nervous, Ms. Satterfield said.
“People are concerned about the documentation of medication in the chart. They don't want to be liable because they're not actually providing medications, and they're counting on patients to report correctly.
“But CMS recognizes that your documentation is only as good as patients’ reporting. It's not an evaluation—you're just documenting what they tell you.
“Ask patients to bring a list of their medications, and the dosage and frequency with which they take them. Put that list in the chart, and ask them at every visit if their medications have changed. This really makes sense—you should know if patients are on ototoxic drugs or medications causing tinnitus or dizziness.”
Standard audiology screening exams will never be a PQRS measure, Dr. Spoor noted.
“PQRS aims to take something that is a best practice but that not everyone is doing—like asking patients about the medications that they're on—and make that into a mainstream practice that audiologists do routinely,” Dr. Spoor said.
“The goal is to make the best practices normal practices so that everybody's providing a high level of care.”
CMS has established a help desk for PQRS assistance, open from 7 a.m. to 7 p.m. CT, Monday through Friday. It can be reached via phone at 866-288-8912 or e-mail at firstname.lastname@example.org.
ROOM FOR EXPANSION
These three measures may be the only ones applicable to audiologists this year, but that will probably change. The Audiology Quality Consortium is working to develop audiology-specific measures.
“It's likely that Congress is going to require more measures in the future, and we want them to be clinically relevant to audiologists,” Ms. Satterfield said.
Since the Physician Quality Reporting System itself is also going to continue to grow, now is the time to get into the habit of reporting, Ms. Satterfield said.
“Even though the penalties for nonparticipation right now may only be two percent on all Medicare claims in a reporting period, Congress is considering expanding them up to 10 percent.
“You may be able to put it off for awhile, but jumping in later will be harder—more measures, more benchmarks, and higher penalties. It's better to get in now and expand gradually.”