How to Measure SLP Value (VS Volume): And how to speak the MIPS language

I heard about a clinician who looked at her perfectly compliant, completely "productive" day on paper and realized she had no idea if any of her patients actually got better. The system was brilliantly designed to measure her speed, her units, and her billing, but it was completely ignoring her actual impact.

So, we know that insane productivity standards like 90%... 95%... lead to issues that have a wide impact from the clinician all the way right down to the patient, right? Now, let’s talk about how we move the needle forward in the battle against these unrealistic expectations. 

How do we shift our focus away from the soul-crushing, winless race for billable units and back to the things that actually matter? It’s time to talk about measuring value.

The Multi-Trillion Dollar Problem 

To understand why value-based care has become a recent buzzword, look at the staggering price tag of our current healthcare system. In 2024, U.S. health care spending reached $5.3 trillion, consuming nearly $1 out of every $5 generated in the entire American economy (Hartman et al., 2026). 

On a human scale, that is the equivalent of billing every single man, woman, and child in America over $16,000 this year (or $64,000 for a typical family of four)... Just to keep the system running.

When we see astronomical healthcare bills, we naturally assume every dollar is being poured into cutting-edge treatments and life-saving care. But the data shatters that assumption: 1 out of every 4 dollars spent in our healthcare system is complete… and total… waste (Levchenko & Chaet, 2022). 

That money isn't saving lives—it is being burned by administrative paperwork, inflated pricing, and low-value care (Laloo & Bansal, 2026). Patients are routinely poked and prodded for tests that don't help them, with nearly a third of all lab orders and billions in imaging serving no medical purpose at all (Wen et al., 2026).

The Ethics of Stewardship 

As clinicians, we are caught in the middle of this. The American Medical Association's Code of Medical Ethics explicitly states that physicians and clinicians have an ethical obligation to be "prudent stewards" of shared health care resources (Levchenko & Chaet, 2022). But how can we be responsible stewards when we are trapped in a fee-for-service system that inherently rewards volume over patient recovery?

Researchers are now trying to stop the escalation of low-value medical orders. These are the tests, procedures, and interventions ordered out of habit, defensive medicine, or misaligned incentives that offer patients minimal clinical benefit while driving up costs and risks (Wen et al., 2026). 

Can you think of anything we as SLPs do that fits this description?

Yes, we add to the problem. BUT we are simultaneously the ultimate antidote to that problem. We can help solve the issue of low-value care

We are the pathway that helps patients avoid those unnecessary surgeries and imaging cascades. But under value-based care, knowing our worth isn't enough; we have to actively prove it.

The Rules of the Game 

Enter MIPS (the Merit-based Incentive Payment System). This isn't an abstract policy; it is a high-stakes report card that directly controls revenue.  

Instead of paying simply for the number of patients they see, Medicare now ties reimbursement directly to quality. And while this is primarily only applicable to Medicare B coverage, it’s important for everyone to understand the concept because sooner or later, we are all going to have to adopt the value-based care model. 

In 2026, performance scores carry a maximum adjustment of almost 9% (up OR down) (CMS, 2026). To feel what that means on the clinic floor, imagine a facility billing $100,000 in Medicare. A top-scoring facility collects a $9,000 bonus, while a low-scoring neighbor suffers a $9,000 pay cut… Creating an $18,000 financial gap on the exact same volume of work.

The math behind your MIPS Final Score is broken down into four weighted categories:

  • Quality: 30%

  • Cost: 30% 

  • Promoting Interoperability: 25% 

  • Improvement Activities: 15% 

(CMS, 2026)

To avoid losing money, you need to hit the performance threshold. It’s as easy, and sometimes as hard, as that.

Measuring What Actually Matters 

So, how do we actually show the system that we are providing high-value care? We look at the Quality category. Under traditional MIPS reporting, you must select a minimum of 6 quality measures, and at least 1 of them absolutely must be an outcome measure or a high-priority measure (Centers for Medicare & Medicaid Services, 2026).

What does this mean? It means this is where our real clinical skills shine. We prove our worth by using validated patient-reported outcome measures (PROMs) and standardized assessments that capture our actual impact on a person's life

Here is how that looks in the real world:

Speech-Language Pathology: 

For SLPs, value is often proven in the most fundamental areas of human existence: communication and swallowing.

Imagine a resident in long-term care with late-stage dementia who is rapidly losing weight. Often, the first instinct is to assume the individual has dysphagia or a poor appetite. However, an SLP performing a functional evaluation might find the swallow is physically fine, but the patient’s "attention-to-task" is the real barrier

By implementing environmental cues and training staff on functional communication during meals, the SLP can help patients gain significant weight, which can facilitate a whole range of other positive outcomes. 

By identifying a functional solution to a medical problem, the SLP proves they are an essential piece of the interdisciplinary puzzle.

I’m going to leave you with 3 tactics you can use to help your patient and to secure payment under MIPS:

  1. Automate capture during the initial evaluation: Integrate PROM administration directly into your initial evaluation EHR workflow rather than reinventing the wheel during every single assessment. Make it easy and make it obvious… And the habit will stick. 

  2. Leverage RTM codes: Utilize Remote Therapeutic Monitoring (RTM) CPT codes to track home exercise adherence and functional status between visits, creating a steady stream of objective data. Data is king after all.

  3. Monitor trajectory quarterly: Track your MIPS score quarterly using the EMR dashboard functions so you can project your payment adjustment and adjust measure reporting before year-end deadlines.

Is this measuring value better than volume? I think so. Is our current system for doing so perfect? Far from it. After all, the productivity lords are still tracking your compliance like Big Brother hiding in the vents. 

One issue you’ve probably already thought of with this system is if your patient doesn’t show any signs of functional improvement, but it has nothing to do with you as a clinician

It’s a very real, very human fear: “Will I be penalized because my patient is simply too sick, too complex, or unable to make physical gains?”

Maybe it’s an 82-year-old post-stroke patient who has hit a firm functional plateau, a client with advanced Parkinson’s disease whose tremors are steadily worsening despite your best efforts, or a patient with severe multi-morbidity who simply lacks the motivation to complete their rehab.

And the short answer to that question is… No. You will not be penalized in those cases. MIPS and value-based payment models are not built on a fairy tale where every single patient makes a 100% full recovery.

Here are 4 rules of thumb when managing complex, non-progressing, or unmotivated patients. Hopefully understanding these mechanics can give you some peace of mind…

1. Don’t cherry pick

The productivity-driven side of healthcare might make you think you should only report data for your “wins.” You know, those patients who jump three functional levels and finish therapy with a back flip and a high-five.

In reality, CMS explicitly forbids this. Submitting only favorable outcome data is officially defined as "cherry-picking," which renders your data incomplete and can instantly trigger a compliance audit (insert gasp here).

To satisfy MIPS requirements, clinicians must meet the 75% data completeness threshold across their eligible patient population through the 2028 performance period. Meeting data completeness does not mean 75% of your patients got 100% better. It simply means you tracked and reported performance data for at least 75% of eligible cases.

CMS explicitly recognizes three distinct categories that count toward your 75% completion target:

  • Performance Met: The patient achieved the measure’s target benchmark.

  • Performance Not Met: The patient did not achieve the target.

  • Denominator Exceptions: Valid clinical, medical, or patient reasons why the target could not be met.

Filing an accurate report for a patient who did not improve due to medical complexity or lack of progress still counts toward your data completeness requirement (phew). So, it’s honest reporting across your real caseload that keeps your score intact.

2. Maintenance of function is high-value care

In therapy, success is not always defined by rapid physical improvement. For progressive neurological conditions, advanced frailty, or palliative rehabilitation, preventing rapid functional decline or maintaining current independence might very well be the goal.

MIPS quality measure sets include measures that specifically evaluate the maintenance of function alongside functional improvement. Evaluating a patient's functional baseline on day one using a standardized scale establishes a realistic starting point. 

When treating progressive illness, stabilizing function or slowing a downward trajectory is valid, evidence-based, high-value clinical care.

3. The system adjusts for risk

CMS recognizes that clinicians and facilities caring for sicker, medically fragile, or socially vulnerable populations face entirely different clinical hurdles.

To ensure providers are not disincentivized from taking on challenging cases, MIPS includes a Complex Patient Bonus. This mechanism awards up to 10 bonus points directly to your overall MIPS Final Score. 

These points are calculated based on your patient panel's Hierarchical Condition Category (HCC) risk scores (which measure medical complexity) and social risk indicators, such as dual-eligibility status for Medicare and Medicaid.

Furthermore, CMS scores quality measures against historical national deciles rather than an absolute pass/fail scale. Clinicians are evaluated relative to national benchmarks for that specific measure, rather than being expected to achieve perfection across every single file (phew again).

4. What Facility-Based Clinicians Need to Know

If you practice in a hospital or post-acute facility setting, your individual quality reporting may look even simpler. Under facility-based measurement, eligible clinicians and groups who perform the majority of their work in hospital environments can have their MIPS quality and cost performance category scores derived directly from their assigned hospital’s Value-Based Purchasing (VBP) score. Not bad, right?

Practical Tactics for the Clinic

When you are treating a patient who isn't progressing, isn't motivated, or is medically limited, here is how to navigate the case ethically and strategically:

  1. Get your baseline early: Use validated outcome measures on evaluation day to document pre-existing cognitive, medical, or functional limitations.

  2. What does the patient value? If a patient seems unmotivated by their goals… then change them. Align therapy with the specific activities of daily living they actually care about most.

  3. Document Document Document: You’ve heard that one before. If a patient cannot complete a test or reach a benchmark due to acute medical instability or illness, document the clinical rationale clearly to support the exception.

  4. Discharge ethically: When a patient reaches a plateau and no longer requires skilled therapy services for improvement or maintenance, ending therapy cleanly is the highest-value decision you can make. It avoids unnecessary billing, prevents low-value care, and keeps your outcome tracking clean. It’s also coincidentally… The right thing to do.

The Bottom Line

Value-based care is not about pretending every patient will make a full recovery. It is about documenting the reality of your care accurately, using healthcare resources wisely, and celebrating meaningful functional wins—even when those wins mean holding the line for a patient who needs us most.

Taking Back Our Practice 

And again, I know, this system is still not perfect. Who wants to do more paperwork when we are already drowning in a sea of it? The administrative burden of tracking MIPS scores and data completeness can feel like just another weight added to shoulders that are already about to buckle and break. But I will measure a patient's actual recovery over counting my billable minutes any day of the week.

Value-based care might be a corporate financial initiative designed to save the system money, BUT at its heart, it aligns with our deepest ethical obligations: to heal people, to use our resources wisely, and to make sure that healing actually lasts.

Next week, let’s get into some more specific ways we can add value in our practice, no matter what the reimbursement system is.

George Barnes MS, CCC-SLP, BCS-S

George is a Board Certified Specialist in swallowing and swallowing disorders who has developed an expertise in dysphagia management focusing on diagnostics and clinical decision-making in the medically complex population. George yearns to make education useful and quality care accessible. With a passion for food and a deep appreciation for the joy and connection it brings to our lives, he has dedicated his life to helping others enjoy this simple, but deep-rooted pleasure.

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