Home Audiology Why Participate in Medicare Quality Reporting? (Even if You Don’t Have To)

Why Participate in Medicare Quality Reporting? (Even if You Don’t Have To)

by Sarah Warren
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Medicare Part B headline on money

If you treat Medicare Part B beneficiaries, you might be required to report quality measures to Medicare.

But even if you are not required to participate this year, you could be included in the future—so it might be a good idea to voluntarily participate now just for practice. You may even choose to opt-in to the program to earn financial incentives if you can participate successfully.

Some clarity

Medicare’s quality reporting program, the Merit-Based Incentive Payment System (MIPS), requires some providers to report their compliance with certain patient interaction measures. A provider’s failure to participate or to reach certain targets triggers a decrease in the provider’s Medicare reimbursement in future years. Successful participation triggers an increase in the provider’s future reimbursement.

Required participation

Only audiologists and SLPS who meet all three of the following criteria (known as low-volume threshold) must participate in MIPS:

  • Receives more than $90,000 in annual Medicare reimbursement.
  • Treats more than 200 Medicare beneficiaries per year.
  • Provides more than 200 Medicare-covered services.

Based on analysis of 2016 Medicare data, ASHA calculates that only a very small portion of members—probably less than 1%—are required to participate in MIPS. Use the Medicare NPI lookup tool to identify your MIPS reporting status.

Elective participation

The criteria for required MIPS participation will most likely broaden to include more audiologists and SLPs—and now is a good time to gain experience with program. You can voluntarily participate in the program, gaining practice with the system without being liable for a future payment penalty or eligible for a bonus. If and when you are required to participate, your transition to MIPS may go more smoothly, increasing your chances of success—and bonuses—with the system.

You can also use voluntary reporting to decide if you want to opt-in to MIPS. If you find you can successfully earn the bonus, you might want to choose to enroll in the program. However, doing so also puts you at risk for a payment reduction if you opt-in unsuccessfully. Historically, across all eligible disciplines, more providers receive a penalty rather than an increase—so ASHA urges members to approach opt-in with a thorough understanding of the risks and opportunities.

Something else to consider: Opting in to MIPS may help you offset Medicare payment reductions from two other sources. In the first, Medicare reimbursement has been cut by 2% annually since 2013. In the second, Medicare’s multiple procedure payment reduction (MPPR) policy applies a small reduction to the value of each service when multiple therapy services (physical therapy, occupational therapy, and/or speech-language treatment) are provided to the same patient on the same day. If you are considering opting in, however, you want to be sure through voluntary participation that you will be successful.

Reporting measures

In this second year of MIPS participation for audiologists and SLPs, quality measures have expanded over the previous year. MIPS comprises four performance categories: quality, cost or resource use, use of electronic health records , and performance of improvement activities.

Only two of these four categories apply to audiologists and SLPs: quality and improvement activities. For required 2020 participants, MIPS results will trigger adjustments of -7% to +7% to 2022 payments.

Review the full measure specifications to see if you meet the reporting requirements for each specific measure. A patient’s characteristics, such as age and diagnosis, as well as the service you provide, determine whether the patient can be included in the measure.

Audiologists. Audiologists must report on at least six of these measures for at least 60% of the applicable cases:

  • #130: Documentation of Current Medications in the Medical Record
  • #134: Screening for Depression and Follow-Up Plan
  • #154: Falls Risk
  • #155: Falls Prevention Plan
  • #181: Elder Maltreatment Screen and Follow-Up Plan (new)
  • #182: Functional Outcome Assessment (new)
  • #226: Tobacco Use: Screening and Cessation Intervention
  • #261: Referral for Otologic Evaluation for Patients with Acute or Chronic Dizziness
  • #318: Falls: Screening for Future Falls Risk (new; must be reported via certified electronic health record technology, not claims).

SLPs. SLPs must report on all five available measures:

  • #130: Documentation of Current Medications in the Medical Record
  • #134: Preventative Care and Screening: Screening for Depression and Follow-up Plan
  • #181: Elder Maltreatment Screen and Follow-Up Plan (new)
  • #182: Functional Outcome Assessment (new)
  • #226: Preventative Care and Screening: Tobacco Use: Screening and Cessation Intervention

Note that the pain assessment and follow-up measure (#131) has been deleted for 2020.

Contact reimbursement@asha.org for more information.

Sarah Warren, MA, is director of ASHA Medicare policy. swarren@asha.org

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