What is the Merit-Based Incentive Payment System?
The Merit-based Incentive Payment System (MIPS) was established by the Medicare Access and CHIP Reauthorization Act of 2015, with implementation in January 2017. MIPS reflects the consolidation of the Centers for Medicare and Medicaid Services (CMS) previous quality programs: the Physician Quality Reporting System (PQRS), the Value-based Payment Modifier (VBPM), and Meaningful Use (MU). MIPS also adds a new performance category, called Improvement Activities (IA).
MIPS ties payment incentives and penalties to defined quality, cost savings, electronic data exchange, clinical practice improvement, and outcome measures and metrics. Audiologists were added as eligible clinicians for MIPS participation beginning in January 2019. Audiology is measured by two metrics: Quality (including patient outcomes), and clinical practice improvement (IA).
For more information about value-based payment, see CMS’s MACRA webpage.
For more information on MIPS and to determine if you are required to report under MIPS, visit the CMS Quality Payment Program (QPP) portal.
What is a Qualified Clinical Data Registry?
A Qualified Clinical Data Registry (QCDR) is a CMS-approved vendor in the business of improving healthcare quality. The vendors specialize in the creation, tracking, and submission of healthcare quality and clinical improvement measures and metrics. Such vendors may assist medical professionals, like audiologists, in developing, operationalizing, tracking and reporting quality measures and metrics.
What is a Qualified Clinical Data Registry Measure?
These are test measures designed to 1) measure an individual’s outcomes following audiology evaluation and treatment, and 2) show the value, efficacy, and utility of a measure prior to being included in the MIPS reporting system. These measures can also be used to track a practice’s own internal quality, performance, patient satisfaction, outcomes measures, and metrics.
QCDR measures are not like other MIPS or Clinical Quality Measures (CQM). You can only report them through a QCDR that has permissions from the measure steward. You cannot report or track a QCDR measure via claims reporting, EHR reporting, registry reporting, or any other reporting mechanism. Currently, Healthmonix is the only vendor that offers a QDCR registry for audiology.
How were the Audiology Quality Measures Developed?
For the development of the audiology MIPS quality measures, the Audiology Quality Consortium (AQC) worked with Healthmonix to create QCDR measures for 2022. The next step in this process is to test the measures. Healthmonix, the Audiology registry vendor, will also assist with measure testing. After testing and acceptance by CMS, these MIPS Quality measures will be available for reporting by audiologists who are required to participate in MIPS, for those who choose to opt-in to try to earn a payment incentive, or for audiologists who wish to voluntarily report. NOTE: Healthmonix is one vendor that offers software systems and integrations that allow for the reporting of current MIPS quality measures, clinical improvement activities, and meaningful QCDR measures. An annual per provider fee is charged to utilize the registry, report to CMS and track outcome measures.
Why Should Audiologists Want to Participate in Quality Reporting?
- The measures and activities demonstrate audiologists’ value to consumers and the healthcare system.
- The activities differentiate audiology from over the counter (OTC)/direct to consumer (DTC) entities, big box retailers, and hearing aid dispensers in the marketplace.
- These activities illustrate the evidence-based, patient-centric practice of audiology.
- The profession needs to obtain data and metrics on the quality and value of audiology evaluation and treatment services to patients and the healthcare system. The profession of Audiology needs to utilize these clinical data in legislative, regulatory, and advocacy initiatives as well as individual clinic improvement activities.
- Audiologists are one of the providers acknowledged by CMS for MIPS reporting and need to remain in parity with other doctoral-level health care providers to improve quality and optimize payment options afforded to the profession.