Just when physical therapists had gotten used to submitting PQRS data, CMS decided to pull the plug on that program and replace it with a brand-new, much beefier quality data reporting initiative: the Merit-Based Incentive Payment System. This program—known as MIPS—is a consolidation of Medicare’s Meaningful Use, Physician Quality Reporting System, and Value-Based Payment Modifier programs. It officially went into effect on January 1, 2017 (with payment adjustments affecting Medicare Part B payments beginning in 2019). According to CMS, providers who participate in MIPS “earn a payment adjustment based on evidence-based and practice-specific quality data.” In other words, you “show you provided high quality, efficient care supported by technology by sending in information in the following categories”:
- Quality (which replaces PQRS);
- Improvement Activities (which is a new reporting component);
- Advancing Care Information (which replaces Meaningful Use); and
- Cost (which replaces the Value-Based Payment Modifier)
These categories are weighted to make up to 100 percentage points—and a provider’s final score dictates the MIPS payment adjustment that will be applied to that provider’s Medicare Part B payments two calendar years later (i.e., the 2017 score dictates the 2019 adjustment, the 2018 score dictates the 2020 adjustment, and so on).
Now, while therapists weren’t considered “eligible professionals” (or EPs) under Meaningful Use, they are EPs under MIPS—and its umbrella program, the Medicare Access and CHIP Reauthorization ACT (MACRA). (Well, those therapists who bill for Medicare Part B or under Critical Access Hospitals that use Method II payments, anyway. ) However, therapists aren’t being added to the EP list until at least the third reporting year of the program—which brings me to my first MIPS must-know:
1. PTs aren’t eligible to participate in MIPS until 2019.
Earlier this year, several rehab therapy practices received confusing letters from CMS regarding their MIPS participation status. So, before we go any further, I want to make sure everyone is crystal clear on the following point: physical therapists, occupational therapists, and speech-language pathologists are still not eligible to officially participate in this quality reporting initiative. (To verify your eligibility status, you can enter your NPI in this form.) According to the APTA, though, “it’s almost a given that PTs will be mandatorily included as early as 2019.”
2. The participation criteria have changed.
CMS recently increased the minimum thresholds for eligible provider participation. Per the Final Rule, in 2018, “eligible clinicians with less than or equal to $90,000 in Part B allowed charges or less than or equal to 200 Part B beneficiaries” are excluded from participation in MIPS. And as of now, there is no opt-in option for providers who are excluded because they only meet one of the minimum criteria. For reference, according to Betsy Hyder—WebPT’s in-house compliance resource—“the minimums are measured from claims submitted in a 12-month period (September 1, 2016 to August 31, 2017).”
That means that, even if small rehab therapy practices were considered eligible providers for the coming year, many would still be participating in MIPS on a voluntary, rather than mandatory, basis—which means they wouldn’t be eligible to reap the financial benefits of the program.
3. Those who do not participate in MIPS cannot reap the financial benefits.
Speaking of financial benefits, let’s talk about what’s at stake with MIPS compliance. In addition to a small annual adjustment to the Part B fee schedule (+.5% through 2019; then +.25% in 2026 and beyond) and a value-based payment adjustment—positive or negative—based on the provider’s final score, providers may face some reputational implications. That’s because, apparently, CMS is releasing participating provider annual scores to the public, so patient-consumers will be able to see their providers rated on a scale of 0 to 100.
4. The MIPS quality reporting measures are similar to PQRS measures.
While MIPS replaces PQRS in its entirety, there are some similarities between the two programs—namely, that providers will continue to report quality measures. As it stands now, most providers are required to report at least six measures—across any combination of quality domains—including one outcome measure. Additionally, most eligible providers must attest that they’ve completed up to four improvement activities as well as fulfill the required advancing care information measures.
5. There are group reporting opportunities.
Individual providers and small practices who don’t meet the minimum threshold for participation on their own may be eligible for group reporting through a new “virtual” group reporting option in which “solo practitioners and groups of 10 or fewer eligible professionals can come together ‘virtually’ to participate in MIPS together for a specific performance period.” (You can learn more about virtual group reporting here.) It’s one way small rehab therapy practices may be able to complete MIPS reporting once PTs, OTs, and SLPs become eligible participants in 2019—even if Medicare maintains its current patient volume and billing criteria.
6. PTs who don’t end up participating in MIPS should not stop collecting meaningful data.
Now, even if you don’t meet the participation criteria—and you decide against joining a reporting group—it doesn’t mean you should stop all data collection efforts. In fact, I strongly encourage therapists to continue building their data stores by committing to collecting meaningful outcomes data on their own. After all, the more data we, as a profession, can amass collectively, the more effectively we can assert our value as care providers and coordinators.
About the Author
Heidi Jannenga is co-founder and president of WebPT, the leading physical therapy software platform for enhancing patient care and fueling business growth. She has more than 15 years of experience as a physical therapist and clinic director, and she’s an active member of the sports and private practice sections of the APTA as well as the PT-PAC Board of Trustees.