The Quality Payment Program (QPP) is a Medicare program that is transitioning payments for outpatient services away from a fee-for-service system to a system focused on payment based on quality and outcomes. The QPP was implemented in 2017 and comprises two tracks: Advanced Alternative Payment Models (A-APMs) and the Merit-Based Incentive Payment System (MIPS). Payment for outpatient services, including audiology and speech-language pathology services, will be tied to participation in one of the two tracks of the QPP.
Alternative Payment Models (APMs) take a variety of forms—accountable care organizations, patient-centered medical homes, bundled payments, and episodes of care—and are usually inclusive of hospital, physician, and post-acute care services. To qualify as an A-APM, additional criteria must be met.
Audiologists and speech-language pathologists (SLPs) have been eligible to participate in the A-APM track since 2017. Successful A-APM participants can receive a 5% lump-sum incentive payment on their Medicare Part B (outpatient) services if Medicare payment or Medicare patient count thresholds are met (e.g., at least 25% of the clinician’s Medicare payments or at least 20% of the clinician’s Medicare patients receive services through the A-APM). An example of an A-APM that currently includes the services of audiologists and SLPs is the Comprehensive Care for Joint Replacement Payment Model.
At this time, there are some Medicare A-APMs for which audiologists and SLPs are eligible. However, to allow more clinicians to qualify for the A-APM incentive payment, the Centers for Medicare & Medicaid Services (CMS) will include payments and patient counts of other payers—Medicaid, private insurance, and Medicare Advantage—in the thresholds beginning in 2019.
Those clinicians not participating in an A-APM may need to participate in MIPS, which focuses on quality improvement and efficiency. Audiologists and SLPs are now included in MIPS, effective January 1, 2019. The MIPS payment adjustment—applied in 2023 based on a clinician's performance in 2021—is +/- 9%.
Given the limited number of A-APMs available to audiologists and SLPs at this time, MIPS will become the primary mechanism to earn positive payment adjustments from Medicare. Clinicians that are eligible for MIPS reporting are benchmarked against peers in to up to four categories of performance. Overall payments for audiology and speech-language pathology services will remain stable under MIPS. However, payments will be distributed based on participants’ performance score with high performing participants receiving a payment increase and low performing participants receiving a decrease. Payment adjustments based on 2020 reporting will apply to 2022 payments, 2021 reporting will apply to 2023 payments, and so forth.
Note: A clinician is only eligible for MIPS if they report their individual National Provider Identifier (NPI) number on the claim form. As such, clinicians working in facilities (e.g., hospitals, skilled nursing facilities) are not eligible for MIPS. Clinicians can use the MIPS Eligibility NPI Look-up Tool to help determine eligibility.
MIPS has four performance categories:
For detailed information on MIPS, see ASHA's guide for audiologists and SLPs.
Questions? Contact ASHA's health care policy team at firstname.lastname@example.org.