The Medicare Merit-Based Incentive Payment System (MIPS)
A Guide for Audiologists and Speech-Language Pathologists
Effective January 1, 2019, the Centers for Medicare & Medicaid Services (CMS) included audiologists and speech-language pathologists (SLPs) in the Merit-Based Incentive Payment System (MIPS). ASHA estimates less than 1% of members are required to participate in MIPS. The MIPS payment adjustment—applied in 2026 based on a clinician's performance in 2025—is +/- 9%.
MIPS participation is separate from the claims-based outcomes reporting requirement for Medicare Part B therapy services, often referred as 'functional limitation reporting' (FLR), which was eliminated for dates of service on or after January 1, 2019.
Although most audiologists and SLPs who are Medicare Part B providers are not required to participate in MIPS, the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 tied annual Medicare payment updates to participation in MIPS or advanced alternative payment models (AAPMs) beginning in 2026. Specifically, clinicians participating in MIPS will be eligible for an annual Medicare Part B payment update of 0.25% and those participating in AAPMs will be eligible for an annual payment update of 0.75%. These payment updates would be in addition to any MIPS incentive or AAPM bonus earned by the clinician. If a clinician elects not to participate in either MIPS or AAPMs, the Medicare payments they receive will remain stagnant indefinitely without a change in the law.
Audiologists and SLPs should thoughtfully consider whether to participate in MIPS or AAPMs. Recent experience indicates that the highest incentive payment for MIPS participation remains below 3% and few AAPMs have quality measures that adequately capture audiology and SLP services. In addition, the cost to participate in MIPS or an AAPM may exceed the reward. The low annual payment updates associated with participation in MIPS and AAPMs along with any potential incentive payment is not likely to fully offset the impact of the Part B payment reductions clinicians have experienced since 2021. That said, clinicians who successfully participated in the Physician Quality Reporting System (PQRS), the predecessor quality reporting program, would likely do as well in MIPS because many of the measures from PQRS are included in MIPS.
Navigating MIPS
- Who Must Participate?
- Exemption from MIPS Reporting
- Opting-In or Voluntary Reporting
- Group Practices: Choosing Individual or Group Reporting
- MIPS Participation and Performance Categories
- How do the Payment Adjustments Apply?
- Other Performance Categories
- Resources
Who Must Participate?
Audiologists and SLPs who exceed the low-volume threshold, are not otherwise exempt, and provide services to Medicare Part B patients in the following settings must participate in MIPS reporting.
- Independent private practices
- Group practices
- University clinics not associated with a hospital medical center
- Outpatient clinics not associated with a hospital medical center
- Critical access hospitals (CAHs) that have elected Method II billing (check with hospital administration)
Clinicians working in facility-based settings (e.g., hospitals, skilled nursing facilities, etc.) are not eligible to participate in MIPS. MIPS reporting only occurs in settings where individual NPI numbers and Current Procedural Terminology (CPT) codes are indicated on claims.
Clinicians can use the MIPS Eligibility and Participation Quick Start Guide [PDF] and the Quality Payment Program Lookup Tool to help determine MIPS eligibility.
See also: How MIPS Eligibility is Determined
Low-Volume Threshold
To reach the low-volume threshold, a clinician must meet all three of the following criteria in a calendar year.
The individual clinician must
- see 200 or more Medicare beneficiaries;
- provide 200 or more covered professional services (defined as a single line item on the claim); AND
- receive $90,000 or more in reimbursement from Medicare.
Clinicians can use the Quality Payment Program Lookup Tool to help determine whether you've met the low-volume threshold and are eligible for MIPS participation.
Exemption from MIPS Reporting
A clinician who provides Medicare Part B services in the appropriate settings can still be exempt from mandatory MIPS reporting for any one of the following reasons.
- The clinician is newly-enrolled in Medicare. In this case, they are exempt for that reporting year.
- The clinician is deemed a qualifying or partially qualifying participant of an alternative payment model (APM).
- The clinician does not exceed the low-volume threshold.
A clinician who is exempt from mandatory reporting for any of these reasons may choose to participate in the MIPS program in one of two ways—opting-in or voluntary reporting.
Opting-In or Voluntary Reporting
A clinician who is exempt from MIPS reporting can still participate in the program through voluntary reporting or by opting-in to MIPS.
Voluntary reporting allows you to practice reporting without being subject to MIPS incentive payments or penalties. This may be helpful if you are considering opting-in or if the MIPS program expands its mandatory reporting criteria to include more clinicians in the future.
Opting-in to the MIPS program allows you to earn the MIPS incentive or risk the MIPS penalty. To opt-in, you can only exceed one or two of the three low-volume threshold criteria in addition to other criteria outlined by CMS. Opting-in might be attractive if you were previously successful under the Physician Quality Reporting System (PQRS). Keep in mind that opting-in subjects you to a positive, neutral, or negative payment adjustment based on your MIPS performance.
Contact CMS for information on how to opt-in or voluntarily report at QPP@cms.hhs.gov, 1-866-288-8292, or 1-877-715-6222 (TTY).
Group Practices: Choosing Individual or Group Reporting
Group practices (two or more clinicians) should decide whether clinicians will report as individuals, as part of the group, or both (individually and as part of the group). Keep in mind that mandatory reporting only applies to individual clinicians, not the group.
If each individual clinician in the group is exempt from MIPS reporting, they are not required to report even if they collectively meet the reporting requirements as a group.
If any individual member of the group is a required to participate in MIPS, the practice can elect to report as a group, though it is not required. When a practice elects to participate in group reporting, all clinicians in the group must report. In this case, clinicians could report as both an individual and as a group. CMS will assess both the individual and group score and use the better score to determine the payment adjustment.
See also: MIPS Individual or Group Reporting and 2024 Virtual Group Tool Kit [ZIP]
Group Practice Reporting Scenario
Scenario: Four physicians and two audiologists see Medicare Part B patients in a private practice. Each individual physician is required to report because they meet all MIPS eligibility criteria. However, the audiologists are not required to report because they are individually exempt.
The private practice has several reporting options in this scenario:
- The audiologists elect not to participate in MIPS and the physicians report as individuals, as required. The group is not reporting.
- The audiologists participate voluntarily to gain experience with the program and the physicians report as individuals, as required. The audiologists would not be subject to the penalty or incentive. The group is not reporting.
- The audiologists opt-in to MIPS and the physicians report as individuals, as required. Like the physicians, the audiologists could earn the incentive but also risk the penalty. The group is not reporting.
- The practice determines they will report as a group. This means everyone in the group, including the audiologists, will be required to report.
MIPS Participation and Performance Categories
MIPS participation and scoring starts over each calendar year. For example, the 2025 performance period begins January 1, 2025, and ends December 31, 2025. Payment adjustments based on 2025 reporting will only apply to Medicare payments in 2027. If you get a different score in the next calendar year (2026), it will only apply to payments made in 2028 and so on. You should begin reporting as close as possible to January 1 of each year to improve your chances of successful participation.
Clinicians participating in the MIPS program receive a composite score based on their performance on each of four performance categories—quality, improvement activities (IAs), promoting interoperability (PI), and cost.
Only three of the four MIPS performance categories currently apply to audiologists and SLPs—quality measures, promoting interoperability, and improvement activities. The associated weight of the cost category will be redistributed to the applicable categories for scoring purposes.
See also: CMS 2024 Measures and Activities for Audiologists and SLPs
Reporting Quality Measures
The quality performance category is based on quality measures developed through a qualified clinical data registry (QCDR) or with legacy measures formerly used in the Physician Quality Reporting System (PQRS). The legacy PQRS measures are primarily process-based—as opposed to outcomes-based—and are more general, such as tobacco-use screening and cessation intervention.
How it Works
Quality measures can be reported in a variety of ways, including through Medicare Part B claims, electronic health records (EHRs), or registries. Most audiologists and SLPs will likely report on their Medicare Part B claims, unless they are connected to a larger practice. The CMS claims submission quick start guide [PDF] includes helpful tips for successful participation for the quality performance category.
Each quality measure includes specifications [ZIP] that indicate when a clinician should report on that measure. These specifications include the service provided (based on CPT codes) and specific patient characteristics (for example, age or diagnosis).
To report on a quality measure, you will add specific MIPS-related G-codes to your claim form for all qualifying visits with a patient. A qualifying visit is when an encounter meets all the specifications required for reporting one or more quality measures.
Benchmark for Successful Participation: Clinicians must report on at least six measures and all qualifying visits for those measures. In 2025, audiologists have 12 measures and SLPs have 13 available for reporting. Successful reporting means that a MIPS quality data code (QDC) indicating performance met for that quality measure was included on the claim.
2025 Quality Measures
The reporting period for the quality performance category is the 2025 calendar year. Reporting in 2025 will determine payment adjustments in 2027, which could be as much as +/-9% in the 2027 payment year.
Clinicians should report on all qualifying visits for at least six quality measures when six measures are available.
Measures for audiologists:
- Documentation of Current Medications in the Medical Record
- Preventive Care and Screening: Screening for Depression and Follow-Up Plan
- Falls: Plan of Care
- Elder Maltreatment Screen and Follow-Up Plan
- Functional Outcome Assessment
- Preventive Care and Screening: Tobacco Use: Screening and Cessation
- Referral for Otologic Evaluation for Patients with Acute or Chronic Dizziness
- Falls: Screening for Future Falls Risk
- Preventive Care and Screening: Unhealthy Alcohol Use: Screening and Brief Counseling
- Screening for Social Drivers of Health
- Preventive Care and Screening: Screening for High Blood Pressure and Follow-Up Documented
- Connection to Community Service Provider: Percent of patients 18 years or older who screen positive for one or more of the following health-related social needs (HRSNs)
Measures for SLPs:
- Documentation of Current Medications in the Medical Record
- Preventive Care and Screening: Screening for Depression and Follow-Up Plan
- Elder Maltreatment Screen and Follow-Up Plan
- Functional Outcome Assessment
- Preventive Care and Screening: Tobacco Use: Screening and Cessation
- Intervention
- Assessment of Cognitive Impairment or Dysfunction for Patients with Parkinson’s Disease
- Screening for Social Drivers of Health
- Connection to Community Service Provider
- Dementia: Cognitive Assessment (New for 2025)
- Dementia: Functional Status Assessment (New for 2025)
- Dementia: Safety Concern Screening and Follow-Up for Patients With Dementia (New for 2025)
- Dementia: Education and Support of Caregivers for Patients With Dementia (New for 2025)
- Amyotrophic Lateral Sclerosis (ALS) Patient Care Preferences (New for 2025)
Reporting Improvement Activities
Improvement activities (IAs) are activities that may not involve direct patient care but can improve the quality of care. An example of an IA is when a clinician implements extended office hours on evenings or weekends. This activity could help decrease the number of emergency room admissions. There are more than 100 IAs to choose from [ZIP], giving audiologists and SLPs some flexibility in this category. The CMS IA quick start guide [PDF] includes helpful tips for successful participation in this performance category.
How it Works
To receive credit for IAs, clinicians must attest that they have been completed through the Quality Payment Program (QPP) Portal. The list of IAs and information on attestation can be found on the CMS QPP website. It is important for clinicians to include documentation in their records to outline and support the actions they have taken to complete the IAs.
Unlike the quality category, selection of IAs is largely driven by the unique circumstances of the clinician and not factors like CPT codes or patient characteristics.
Benchmark for Successful Participation: Beginning in 2025, a clinician must report on at least two IAs to successfully participate in this category. Each IA must be performed during a single, continuous 90-day period (or longer) during the calendar year unless otherwise stated in the activity description.
Reporting Promoting Interoperability
The MIPS Promoting Interoperability (PI) performance category is designed to incentivize the electronic exchange of information using certified electronic health record technology (CEHRT). Policymakers believe that this electronic exchange of health information improves patient access to their health information; improves care coordination between healthcare providers; and allows for the systemic collection, analysis, and interpretation of healthcare data to improve the quality and outcomes of care. The PI Quick Start Guide developed by CMS provides greater detail on reporting for this category. The full measure specifications are also available in the QPP Resource Library [ZIP].
PI Measures
ASHA members will likely qualify for exclusions to reporting on several of these measures and must apply for these exclusions as part of the data submission process.
| Objectives | Measures | Measure Exclusions |
Available Points |
|---|---|---|---|
| e-Prescribing | e-Prescribing | Any MIPS eligible clinician who writes fewer than 100 permissible prescriptions during the performance period. | 1-10 points |
| e-Prescribing | Query of PDPM |
(1) Any MIPS eligible clinician who is unable to electronically prescribe Schedule II opioids and Schedule III and IV drugs in accordance with applicable law during the performance period. (2) Any MIPS eligible clinician who writes fewer than 100 permissible prescriptions during the performance period. (3) Any MIPS eligible clinician for whom querying a PDMP would impose an excessive workflow or cost burden prior to the start of the performance period they select in CY 2023. |
10 points |
| Health Information Exchange |
Option 1 Support Electronic Referral Loops by Sending Health Information |
Any MIPS eligible clinician who transfers a patient to another setting or refers a patient fewer than 100 times during the performance period. | 1-15 points |
| Health Information Exchange |
Option 1 Support Electronic Referral Loops by Receiving and Reconciling Health Information |
Any MIPS eligible clinician who receives transitions of care or referrals or has patient encounters in which the MIPS eligible clinician has never before encountered the patient fewer than 100 times during the performance period. | 1-15 points |
| Health Information Exchange | Option 2 | No exclusion available | 30 points |
| Health Information Exchange | Option 3 | No exclusion available | 30 points |
| Provider to Patient Exchange | Provide Patients Electronic Access to Their Health Information | No exclusion available | 1-25 points |
| Public Health and Clinical Data Exchange |
Report to the following public health or clinical data registries:
|
Generally speaking, the exclusions are based on the following criteria:
|
25 points for the objective |
|
Public Health and Clinical Data Exchange |
Option to report one of the following public health agency or clinical data registry measures:
|
Optional measures (no exclusions available) |
5 bonus points |
How It Works
Clinicians subject to this performance category must report on the PI measures for a minimum of 180 days continuously. In other words, the performance period is not a full calendar year but rather roughly 6 months (e.g. January 1 – June 30). There are 3 ways to submit data:
- Sign in and attest. (You can sign in to your account on the Quality Payment Program website and manually report Promoting Interoperability measures.)
- Sign in and upload. (You or a third party intermediary can sign in to your account on the Quality Payment Program website and upload a file in a CMS-approved format.)
- Direct submission via Application Programming Interface (API). An API is an authorized third party intermediary such as a Qualified Clinical Data Registries (QCDRs) or a Qualified Registries that can perform a direct submission.
How do the Payment Adjustments Apply?
Depending on the outcome of 2025 reporting, a positive or negative payment adjustment of as much as 9% will be applied on all 20267 Medicare claims submitted for services provided by the individual clinician. Clinicians exceeding the benchmark for successful participation in each of the performance categories are eligible for positive payment adjustments and those who do not exceed the benchmark are subject to a negative payment adjustment.
MIPS is tracked by the Taxpayer Identification Number (TIN) of the practice that submitted the claim with the National Provider Identifier (NPI) of the audiologist or SLP listed on the claim as the "rendering provider." This means that you must meet benchmark requirements in every practice that uses your NPI on the claim as the rendering provider.
Other Performance Categories
Although there are four performance categories under the MIPS program, only quality measures, promoting interoperability, and improvement activities currently apply to audiologists and SLPs, as outlined above. The remaining category—cost—does not currently apply due to a lack of relevant metrics for audiologists and SLPs.
Cost: This performance category measures a clinician's cost of care and compares it to a predetermined benchmark. This may be difficult to measure for audiologists and SLPs, as they do not control health care spending and care coordination in the same manner as primary care physicians. As such, this performance category will not be applicable to audiologists and SLPs during the 2025 performance period. Its associated weight in the clinician's total composite performance score will be redistributed to the other MIPS performance categories.
Resources
- CMS: QPP Resource Center
- ASHA: The Medicare Quality Payment Program: What Audiologists and SLPs Need to Know
Questions? Contact ASHA's health care policy team at reimbursement@asha.org.
