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 whenever possible to avoid payment penalties. More audiologists may be required to become mandatory reporters as MIPS evolves making experience with the program important.
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 or performance category, an audiologist must submit different amounts of data in order to meet the requirements. For example, one quality measure may require a submission once per calendar year, but another measure may require a submission for every visit throughout the entire year. Compliance with the interoperability reporting requires attestation of the use of an approved-electronic health record product for 180 continuous days in a calendar year.
Small audiology practices submit quality measures through Medicare Part B claims, often adding a quality code to a Medicare Part B beneficiary’s claim. There are a number of alternative submission options depending on if you report as an individual or a group. See the CMS Quality Payment Program website for more information.
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.
For more information on MIPS APMs, see the CMS website: MIPS Alternative Payment Models (APMs).
Audiologists have been eligible to participate in the A-APM track since 2017. Beginning in performance year 2024, successful A-APM participants can receive an increased physician fee schedule payment update based on the qualifying APM participant (QP) conversion factor ( e.g., 0.75% instead of 0.25%) on their Medicare Part B (outpatient) services if Medicare payment or Medicare patient count thresholds are met (e.g., at least 50% of the clinician’s Medicare payments or at least 35% of the clinician’s Medicare patients receive services through the A-APM). Additionally, 75% of a participant’s practices must be using certified electronic health record (EHR) technology. An example of an A-APM that currently includes the services of audiologists is the Comprehensive Care for Joint Replacement Payment Model.
At this time, there are some Medicare A-APMs for which audiologists are eligible. However, to allow more clinicians to qualify for the A-APM incentive payment, the Centers for Medicare & Medicaid Services (CMS) has an All-Payer Advanced Alternative Payment Model Option that includes payments and patient counts of other payers—Medicaid, private insurance, and Medicare Advantage—in the thresholds.
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 and the CMS requirements for a particular measure.
Penalties and Incentives
For audiologists who are required or opt-in to participate in MIPS, the penalty/incentive for the performance year 2025 is ±9%.
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.
- 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.
Learn more about reporting MIPS measures.