Under the final Quality Payment Program (QPP) rule for 2020, the Centers for Medicare and Medicaid Services (CMS) finalized a new Audiology Specialty Measure Set for audiology participation in the Quality category of the Merit-Based Incentive Payment System (MIPS) (2020 performance period/2022 payment year).

Audiologists were included as “eligible clinicians” in the QPP for the first time in 2019. There are two paths to participation under the QPP—Merit-Based Incentive Payment System or Advanced Alternative Payment Models. MIPS will be the pathway most feasible for audiologists, as the new Specialty Measure Set retains the former Physician Quality Reporting System (PQRS) measures that audiologists once reported to CMS.

Audiologists are subject to payment bonuses or penalties based on quality and improvement activities. Audiologists required to report effective January 1, 2020, will see payment adjustments effective in 2022. Successful reporting under MIPS might result in a payment bonus of up to nine percent, though a nine percent bonus is unlikely. Conversely, failure to meet reporting benchmarks may result in up to a nine percent reduction in reimbursement. 

CMS plans to restructure MIPS participation in the 2021 performance year through the development of its MIPS Value Pathways (MVP) concept. The goal of the MVP framework is to develop measures more relevant to a clinician’s scope of practice.

Required Participants

The Academy estimates that most audiologists will not be required to participate in the QPP for 2020. You may check participation status with CMS at https://qpp.cms.gov/participation-lookup. CMS anticipates this tool will be updated with 2020 MIPS eligibility in February 2020.

To be required to report under QPP, clinicians must meet all of the following requirements: 

Clinicians or groups that have billed $90,000 or more in allowed charges under the Medicare Physician Fee Schedule (MPFS), furnished to Medicare Part B Fee-for-Service (FFS) beneficiaries (including Railroad Retirement Board and Medicare secondary payer)

Clinicians or groups that provide care to 200 or more Medicare Part B FFS beneficiaries

Clinicians or groups that provide more than 200 distinct procedures to Medicare Part B beneficiaries

Participants may submit data as an individual or as part of a group. Individual clinicians are identified by a unique combination of individual National Provider ID (NPI) and Tax ID Number (TIN). Clinicians who assigned their Medicare billing rights to a group organizational TIN can submit data as part of a group or as an individual.

Low-Volume Threshold Exclusion

Most audiologists will meet at least one of the following low-volume criteria and be automatically excluded from MIPS participation. 

Have ≤ $90K in Part B allowed charges for covered professional services, 

Provide care to ≤ 200 Part B enrolled beneficiaries, OR

Provide ≤ 200 covered professional services under the MPFS.

Voluntary Reporting and Opt-In Option

Audiologists may choose to voluntarily report under MIPS. CMS also offers an “opt-in” option, distinct from voluntary reporting. 

Providers who meet one or more criteria for the low-volume exception may “opt-in” to MIPS. However, if a provider elects to participate, status cannot change for the performance period. The provider will be subject to performance-based payment adjustments, either positive or negative, in 2022. 

View the CMS Fact Sheet on Voluntary Reporting at www.audiology.org/mips-fact-sheet.

MIPS Performance Categories

Four performance categories are considered for a provider’s final score, which determines the payment adjustment. For audiologists, the 2020 reporting/2022 payment year will remain limited to the Quality and Clinical Improvement categories.

Number One: Quality

Included in the new Audiology Specialty Measure Set for MIPS are the following:

  • #130 Documentation of Current Medications in the Medical Record
  • #134 Screening for Clinical Depression and Follow-Up Plan
  • #154 Falls Risk Assessment
  • #155 Falls Plan of Care
  • #181 Elder Maltreatment and Follow-Up Plan (new)
  • #182 Functional Outcomes Assessment (new)
  • #226 Preventative Care and Screening: Tobacco Use: Screening and Cessation Intervention
  • #261 Referral for Otologic Evaluation for Patients with Acute or Chronic Dizziness
  • #318 Falls Screening for Future Fall Risk (new)

Audiologists must report on six measures for at least 70 percent of eligible patients. As of this writing, details for reporting are not yet finalized.

Number Two: Promoting Interoperability (PI)

Audiologists remain exempt from this category.

Number Three: Improvement Activities

This category includes an inventory of activities that assess how providers improve care processes, patient engagement, and access to care. For an inventory of eligible activities, see: https://qpp.cms.gov/mips/improvement-activities. Improvement activities may be submitted to CMS through registries, some EHRs, and the CMS QPP Portal. 

Number Four: Cost

The cost of care provided will be calculated by CMS based on Medicare claims. Audiologists remain exempt from this category. 

Carrie Kovar is a government relations consultant to the American Academy of Audiology.