Merit Based Incentive Payment System (MIPS) Implementation (2019)

ADA will be hosting a webinar on the MIPS program on Thursday, December 20, 2018 at 1PM EST.

 

 

STEP #1: DETERMINE IF YOU ARE REQUIRED TO PARTICIPATE IN THE MIPS PROGRAM.

  • Go to MIPS Participation Status link.
  • Insert your National Provider Identifier in the box provided.
  • Only the Performance Year (PY) 2018 Participation Status is CURRENTLY available. The Centers for Medicare and Medicaid Services (CMS) plan to have the site updated by early December 2018 and make a PY2019 Participation Status Tool Available.
    • The PY2018 Participation Status summary, for your NPI, will give you a snapshot of your Medicare claims data for determination periods between September 1, 2016 – August 31, 2017 or September 1, 2017 – August 31, 2018.
      • While this snapshot will provide you with information on your status for 2018 Participation ONLY, it does give you some interim information on your enrollment date, the number of Medicare patients you have seen in the review period, and the amount of Medicare allowed charges you have billed during the review period.
      • If, when you check your MIPS eligibility status on the PY2019 tool (which is not yet available), it indicates that you are eligible to report because of participation in an Alternative Payment Model (APM), please immediately reach out to the practice manager of your facility to determine your specific reporting requirements and mechanisms (as the claims-based reporting option might not be available to you).
        • Typically, APMs only exist in large hospitals, medical centers, and multi-disciplinary clinics.

Audiologists are MIPS EXEMPT for participating in the MIPS program if, individually, they:

  1. Have $90,000 or less in Medicare Part B allowed charges for covered professional services; OR
  2. Provide care to 200 or fewer Medicare beneficiaries; OR
  3. Provide 200 or fewer covered professional services under the Medicare Physician Fee Schedule (PFS).

These exemptions are collectively called the low volume threshold. 99% of individual audiologists in the United States, whose practice is not enrolled in an Alternative Payment Model (APM), will be exempt from MIPS reporting in 2019.

STEP #2: DETERMINE IF YOU WANT TO VOLUNTARILY REPORT MIPS MEASURES OR OPT IN TO THE MIPS REPORTING SYSTEM.

  • Exempt audiologists (audiologists who do not meet the low volume threshold) may decide to voluntarily participate in the MIPS program. This can be accomplished by two means:
    • Voluntary Participation:
      • Audiologists will not formally sign up/enroll in this type of reporting.
      • Audiologists can participate via the same mechanism they reported Physician Quality Reporting Systems (PQRS) Measures.
        • Reporting G-Codes via Medicare Part B claims.
      • Audiologists will also “attest” to the Improvement Activities (IA).
    • Opt-In Participation:
      • Audiologists will officially and formally “opt in” (the form or process is not yet available).
      • Audiologists can participate via the same mechanism they reported Physician Quality Reporting Systems (PQRS) Measures.
        • Reporting G-Codes via Medicare Part B claims.
      • Audiologists will also “attest” to the Improvement Activities (IA).
      • Audiologists would be eligible for payment incentives and payment reductions, based upon their overall MIPS score and performance.

The Academy of Doctors of Audiology is not recommending that its members “opt in” to the MIPS program in 2019. Instead, we are advocating that our members voluntarily participate in the MIPS program in 2019. For more information on voluntary participation, please review the Voluntary MIPS Participation Guide attached.

Resources:

Additional guidance will be provided as more information becomes available from the Centers for Medicare and Medicaid Services (CMS). Please watch your email for more information in early 2019.

For questions, please contact Kim Cavitt or call 773-960-6625.

 


 

Merit Based Incentive Payment System (MIPS) Voluntary Reporting for 2019

STEP # 1: REGISTER FOR AN ENTERPRISE IDENTITY MANAGEMENT (EIDM) ACCOUNT

This account will allow you to track your Quality Payment Program (QPP) performance and score.

 

 

DO NOT INADVERTENTLY OPT IN TO THE MIPS PROGRAM
AS PART OF EIDM REGISTRATION PROCESS.

STEP #2: COMPLETE AND REPORT MIPS QUALITY MEASURES

  • MIPS Quality Measures are reported EXACTLY the same way by which your practice reported for the Physician Quality Reporting System (PQRS) from 2012-2016.
    • The six quality measures are the EXACT same six quality measures that audiologists reported for PQRS is 2016. They are:
      • Documentation and verification of current medications in the medical record.
      • Screening for clinical depression and follow-up plan.
      • Falls Risk Assessment
      • Falls Risk Plan of Care
      • Screening for Tobacco Use/Cessation
      • Referral for otologic evaluation for patients with acute or chronic dizziness.
  • Audiologists must complete quality measures and report on their outcomes for at least 50% of all eligible patients.
  • Audiologists can get a refresher on “what” and “how” to report these measures at:
  • Audiologists who are voluntarily reporting MIPS Measures will report via their CMS 1500 claim form or 857 formatted electronic claims using the PQRS Measure codes (just as they did PQRS).

STEP #3: COMPLETE AND ATTEST TO IMPROVEMENT ACTIVITIES

  • MIPS also has a category known as Improvement Activities.
  • Improvement activities are activities designed to improve clinical practice.
  • Some improvement activity options that are applicable to an audiology practice include:
    • Collection and follow-up on patient experience and satisfaction data on beneficiary engagement.
    • Collection and use of patient experience and satisfaction data on access.
    • Completion of an Accredited Safety or Quality Improvement Program.
    • Completion of the AMA STEPS Forward program.
    • Depression screening.
    • Engage Patients and Families to Guide Improvement in the System of Care.
    • Engagement of New Medicaid Patients and Follow-up.
    • Evidenced-based techniques to promote self-management into usual care.
    • Implementation of condition-specific chronic disease self-management support programs.
    • Implementation of documentation improvements for practice/process improvements.
    • Implementation of episodic care management practice improvements.
    • Implementation of fall screening and assessment programs.
    • Implementation of formal quality improvement methods, practice changes, or other practice improvement processes.
    • Implementation of improvements that contribute to more timely communication of test results.
    • Implementation of practices/processes for developing regular individual care plans.
    • Implementation of Use of Specialist Reports Back to Referring Clinician or Group to Close Referral Loop.
    • Improved Practices that Disseminate Appropriate Self-Management Materials.
    • Improved Practices that Engage Patients Pre-Visit.
    • Integration of patient coaching practices between visits.
    • Leadership engagement in regular guidance and demonstrated commitment for implementing practice improvement changes.
    • Participation in a 60-day or greater effort to support domestic or international humanitarian needs.
    • Participation in Joint Commission Evaluation Initiative.
    • Participation in Population Health Research.
    • Participation in private payer clinical improvement activities.
    • Participation in User Testing of the Quality Payment Program Website (https://qpp.cms.gov/).
    • Practice Improvements that Engage Community Resources to Support Patient Health Goals.
    • Promote Use of Patient-Reported Outcome Tools.
    • Provide Clinical-Community Linkages.
    • Provide Education Opportunities for New Clinicians.
    • Provide peer-led support for self-management.
    • Regular training in care coordination.
    • Regularly assess the patient experience of care through surveys, advisory councils and/or other mechanisms.
    • Tobacco use.
    • Unhealthy alcohol use.
    • Use evidence-based decision aids to support shared decision-making.
    • Use of telehealth services that expand practice access.
      • Each audiologist must complete at least four of these activities listed above and each activity must be performed for 90 days or more during 2019.
  • Audiologists will attest to their performance of these improvement activities at the EIDM site (https://qpp.cms.gov/login).
  • Audiologists can learn more about improvement activities at:
  • https://qpp.cms.gov/mips/improvement-activities
  • https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/Improvement-Activities-Performance-Category-fact-sheet.pdf

For questions, please contact Kim Cavitt or call 773-960-6625.