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Medicare QPP Rules for 2020 By Carrie Kovar

U nder 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

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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)

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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

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(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.

1. Have :-::; $90K in Part B allowed charges for covered professional services,

2 . Provide care to :-::; 200 Part B enrolled benefi­ciaries, OR

3. 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.

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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

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• #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 .

for a provider's final score, which determines Number Two: Promoting Interoperability (Pl)

the payment adjustment. For audiologists, the Audiologists remain exempt from this category. 2020 reporting/2022 payment year will remain limited to the Quality and Clinical Improvement Number Three: Improvement Activities

categories. This category includes an inventory of activ -

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

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ities 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 -activi ­ties. 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 . G

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

Resources

CMS offers resources on MIPS participation . Visit https://qpp .

ems.gov/about/resource-library . In addition, the Academy will

post updated OPP information on www .audiology.org.

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