In 2019, most audiologists were voluntary reporters within the MIPS program. The AQC recommends that (1) all audiologists learn the MIPS program by reporting quality measures with each Medicare Part B service provided and (2) remain voluntary to avoid any payment penalties. More audiologists may be required to become mandatory reporters in 2021 or thereafter.
There are two main ways to participate in MIPS: as an individual or as a group. The National Provider Identifier (NPI) and tax identification number (TIN) drive identification of individuals. Reporting as an individual, measures a single provider’s outcomes, with incentives and penalties applicable only to that provider. A group describes a set of two or more eligible providers, all sharing a common TIN, regardless of the specialty or practice setting. CMS assesses payment incentives and/or penalties based on the group’s outcomes and apply them to all individuals billing through the TIN. Audiologists must report as individuals if they meet the mandatory reporting requirements, but they (audiologists) can also elect to report as a group. If an audiologist reports as an individual and as part of a group, CMS will use the higher of the two scores to apply the payment adjustment.
Reporting through the MIPS program is based on a calendar year—January 1 through December 31. Depending on the measure, an audiologist must submit different amounts of data in order to meet the requirements. For example, one measure may require a submission once per calendar year, but another measure may require a submission for every visit throughout the entire year. The requirements change depending on the number of quality measures that eligible providers must report each year. The AQC website will provide updated information as available.
Small audiology practices submit quality measures through Medicare Part B claims, often adding a quality code to a Medicare Part B beneficiaries claim. Registered groups of 25 or more can submit quality measures through the CMS Quality Payment Program website.
ACOs
Accountable Care Organizations (ACOs) that are not participating in the Advanced Alternative Payment Models (AAPMs) are subject to MIPS. Also, ACOs that participate in AAPMs but do not meet the Qualifying APM Participant (QP) threshold are subject to MIPS.
In 2018, the requirements for ACOs changed. MIPS has four performance areas: (1) Quality, (2) Improvement Activities, (3) Promoting Interoperability, and (4) Cost. However, ACOs report only one area—Quality. The audiology practice is responsible for reporting the remaining three areas. If you or your practice participates with an ACO, you must determine how much data the ACO is collecting and what categories it reports.
Scoring for the four performance areas differs for MIPS versus MIPS APM.
Submission Options
Submitting to MIPS will vary, depending on how you report: as an individual, group, or both; the size of the practice; the information technology used; and performance categories being reported. To report as a group, you must meet the definition of a group at ALL times during the performance period (January 1 – December 31). A group is two or more eligible providers who bill under the same tax identification number (TIN) and have reassigned their billing rights to the TIN.
MIPS submissions differ based on the performance category as outlined below. Many audiologists will use claims submissions, but others may use registries or electronic health records, depending on what is available in your particular practice setting. Groups can use the CMS web interface if they are pre-registered.
Quality: Electronic Health Records (EHR), Qualified Registry, Qualified Clinical Data Registry (QCDR), CMS Web Interface, Claims, Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS Survey
Improvement Activities: Attestation, EHR, Qualified Registry, QCDR
Promoting Interoperability: Attestation, EHR, Qualified Registry, QCDR, CMS Web Interface
Cost: No submission required.
Penalties and Incentives
For audiologists who are REQUIRED to report the penalty/incentive for the performance year 2020 (which will be assessed by way of 2022 traditional Medicare payments for covered services) is ±9%, based upon your overall MIPS score for quality reporting and Clinical Improvement attestation.
An audiologist, group practice, or virtual practice’s score is made up of two performance categories: Quality (85% of total score) and Clinical Improvement (15% of total score).
Special Statuses
Two special statuses could apply to audiology:
- Small practice – Defined as a group of 15 or fewer clinicians who bill under the practice’s tax identification number (TIN).
- An audiologist, group practice, or virtual group will earn 2× the points for each improvement activity that they submit.
- An audiologist, group practice, or virtual group who submits at least one Quality measure will also receive six bonus points in the Quality performance category.
- An audiologist, group practice, or virtual group will earn 2× the points for each improvement activity that they submit.
- Rural – Defined in one of the following ways:
- An audiology practice that operates in a zip code designated as “rural” using the most recent Health Resources and Services Administration (HRSA) data.
- A group practice where 75% or more of the clinicians billing under the practice’s TIN are in a zip code designated as “rural” using the most recent HRSA data.
- A virtual group where 75% or more of the clinicians billing under the practice’s TIN are in a zip code designated as “rural” using the most recent HRSA data.
- An audiologist, group practice, or virtual group will earn 2× the points for each improvement activity that they submit.
Reporting Periods
- For 2020, the submission window (for reporting on Clinical Improvement and Quality performance categories) opened on January 2, 2020, and closed on April 30, 2020.
- Performance feedback reports and targeted review for performance year 2019 open on July 2, 2020.
- The targeted review window closes on August 31, 2020.
- The performance year 2019 payment adjustments go into effect on January 1, 2021.
Learn more about reporting MIPS measures.