Question 1: How do I know if I have to participate in the Quality Payment Program (QPP)?
Answer: Only a few audiologists will have to participate in the QPP – because few audiologists have more than $90,000 in allowed charges. You can go to the CMS website to determine if you are required to participate in the QPP based on old data but the final determination for 2019 will be based on your 2019 billing figures.
Question 2: What are the low-volume exclusion criteria under QPP?
Answer: at page 928 The Final Rule states that:
“After consideration of the public comments received, we are finalizing our proposal to modify the definition of low-volume threshold at §414.1305, to mean that for the 2021 MIPS payment year and future years, that eligible clinicians or groups who meet at least one of the following three criteria during the MIPS determination period will not exceed the low-volume threshold: (1) those who have allowed charges for covered professional services less than or equal to $90,000; (2) those who provide covered professional services to 200 or fewer Part B enrolled individuals; or (3) those who provide 200 or fewer covered professional services to Part B-enrolled individuals.“
Question 3: I meet the exclusion criteria for QPP. How may I voluntarily participate in MIPS?
Answer: As of December 20, 2018, CMS has not determined when or how audiologists can voluntarily enroll in MIPS. Please check the Academy website for MIPS updates. If you do wish to enroll, you should be collecting quality data on all of your patients during 2019, the data can probably be submitted later in 2019. Note once you opt-in for 2019 you will be locked in for that year.
Question 4: Is the $90k threshold based on 2018 charges?
Answer: No, it will be based on 2019 allowed charges.
Question 5: For the few audiologists who have to participate in MIPS (because their allowed charges exceed $90k annually) how do they enroll in MIPS?
You will be automatically enrolled but to participate successfully you should check the Quality Payment Program (QPP). Here you will be able to download the user guide for QPP Access and Role Management. Also, check the CMS QPP resource library.
Please send your questions to Susan Pilch.
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