Did you know that at the end of 2016, the Physician Quality Reporting System (PQRS) ended and was replaced by CMS’ new Quality Payment Program (QPP)? This means that 2016 was the final year in which providers, including audiologists, were eligible to participate in the PQRS program. 

The year 2017 marks the first performance year for CMS’ new QPP, with payment adjustments being distributed in 2019. In the first two years of the Merit-Based Incentive Payment System (MIPS), the only providers considered as eligible professionals to participate in the program are the following—physicians, physician assistants, certified registered nurse anesthetists, nurse practitioners, clinical nurse specialists, and groups that include such professionals. Audiologists are ineligible to formally participate in the new QPP during the first two years of the program (2017 and 2018); however, there are opportunities for voluntary or practice reporting. 

What Do Audiologists Need to Know About the End of PQRS and the Transition to MIPS/ Advanced Alternative Payment Models (APMs)?

It is important to note that audiologists are ineligible to participate in MIPS for at least the first two years (2017, 2018). The Secretary of the U.S. Department of Health and Human Services (HHS) has the authority to include other professionals, including audiologists, beginning in 2019. This means that audiologists will not be required to report on anything in 2017, but will have the option to “practice” reporting on measures through MIPS. 

What Are the Options for Participation in the QPP?

There are two pathways for participation in the QPP. The first is through the MIPS, and the second is through APMs. MIPS streamlines existing CMS quality programs including PQRS, the Value Modifier Program (VM) and the Medicare Electronic Health Record (EHR) Incentive Program. Under MIPS, payment adjustments will now be calculated across four categories—quality, clinical practice improvement activities, advancing care information, and resource use. 

An APM is a payment approach that gives added incentive payments to provide high-quality and cost-efficient care. CMS anticipates that most providers will participate in the QPP through MIPs in the initial years of the program, hence the Academy’s focus on this pathway.

Why Should I “Practice” Reporting or Report Voluntarily When Audiologists Are Technically Not Required to Participate in These Programs Until 2019?

Voluntary reporting is exactly that—voluntary. Reporting is not required; however, because reporting will be similar to what you are reporting under PQRS, you may consider the option to continue reporting. This will allow you to become familiar with the new program without being subject to penalties. CMS has also pledged to offer feedback reports to voluntary reporters allowing providers to track their progress and become familiar with this new system. 

We fully expect that CMS will issue further guidance about voluntary reporting throughout 2017. Again, there will be no penalty adjustment for participating on a voluntary basis. If you do experience any difficulty or denials that you think are related to your voluntary participation in MIPS, please immediately contact your Medicare contractor and e-mail the Academy at reimbursement@audiology.org

What Can I Voluntarily Report On Under MIPS?

There are four performance categories under MIPS: quality, improvement activities, advancing care information, and cost/resource use. 

Audiologists Are Unable to Report On Measures in or Be Assessed in the Advancing Care Information or Cost Categories 

The Cost category will be calculated for eligible clinicians (not audiologists) in 2017, but it will not be used to determine a payment adjustment. The Advancing Care Information category replaces the Medicare EHR Incentive Program, also known as Meaningful Use. Audiologists were excluded from the Meaningful Use program; therefore, do not currently have applicable measures to (voluntarily) report under MIPS. This means that audiologists will not be able to report, even voluntarily in these two categories, leaving the Quality and Clinical Improvement Activities categories available for practice reporting. Note: audiologists may still not have applicable measures in these categories by 2019. CMS has determined that they will reweight other categories to determine composite scores in these situations. 

Quality and Improvement Activities

Audiologists will be able to voluntarily report in these two categories. Quality reporting will maintain similar, if not the same, measures and process as PQRS reporting. Clinical Improvement Activities is a new category in which most providers select up to four improvement activities for a minimum of 90 days. Groups with 15 or fewer participants or those in rural or health professional shortage areas only need to demonstrate that you completed up to two activities for a minimum of 90 days. Many of these measures involve beneficiary engagement and improving the experience of and communication with patients. 

How Do I Report Under MIPS?

Quality Reporting 

Under MIPS, eligible clinicians are directed to report up to six quality measures, including an outcome measure, for a minimum of 90 days. A list of all measures can be viewed on CMS website. For audiologists reporting voluntarily, all six measures that audiologists were eligible to report on through PQRS are currently available for reporting under MIPS. 

Clinical Improvement Activities Reporting 

For most participants under MIPS, eligible providers must attest that they have completed up to four improvement activities for a minimum of 90 days. These requirements are different for groups with fewer than 15 participants or if you are in a rural or health professional shortage area. In these cases, providers only need to attest that they have completed up to two activities for a minimum of 90 days. A full list of clinical practice improvement activities in a searchable format is also available on CMS’ QPP website. To report via “attestation” means to report through a secure mechanism, specified by CMS, and submit the required data for Clinical Practice Improvement Activities performance category. 

Did I Need to Start “Voluntarily” Reporting on January 1, 2017? 

The performance period for the first year of MIPS is set to begin on January 1, 2017; however, CMS has indicated that they intend to allow providers to “pick their pace” in terms of participation during this first performance period. In 2017, eligible physicians and other clinicians will have multiple options for participation to ensure they do not receive a negative payment adjustment in 2019. Again, audiologists are not eligible for full participation in 2017, but may voluntarily report. Audiologists will not receive a payment adjustment (negative or positive) for the 2017 performance period. 

The following are three options for participation in 2017. As you will see, providers may choose to begin on January 1 or may opt to adopt a more flexible performance timeline. 

First Option: Test the Quality Payment Program 

If providers submit a minimum amount of 2017 data to Medicare (for example, one quality measure or one improvement activity for any point in 2017), they will avoid a negative payment adjustment. This first option is designed to ensure that providers’ systems are working and that people are prepared for broader participation in 2018 and 2019. This option provides a learning opportunity to adjust to the new system. 

Second Option: Participate for Part of the Calendar Year 

Providers may choose to submit MIPS information for 90 consecutive days. This means that the first performance period could begin later than January 1, 2017, and practices could still qualify for a small positive payment adjustment. 

Third Option: Participate for the Full Calendar Year 

For practices that are ready to go on January 1, 2017, they may choose to submit QPP information for a full calendar year. This means the first performance period would begin on January 1, 2017. Providers reporting for a full year would likely receive a higher positive payment adjustment. 

The Academy will continue to keep its members informed as more information on MIPS and voluntary reporting becomes available. For more information, visit the Academy’s website and search keywords “PQRS” or “MACRA.” You can also attend “The End of PQRS, the Beginning of MIPS,” a learning module available at AudiologyNOW! 2017 in Indianapolis.