On the first of January 2019, physical therapists who treat patients under Medicare Part B became eligible to participate in MIPS and some can even face a form of monetary penalty for non-compliance. Prior to this, physical therapists had not been able to participate in MIPS at all. Here’s what you need to know to get you up to speed with MIPS and its reporting requirements.
The Merit-based Incentive Payment System (MIPS) is one of the two ways that CMS rewards clinicians’ values and outcomes under the Quality Payment Program (QPP).
Under MIPS, you report data in four areas through which your performance is measured. These areas are also called performance categories and they make up your final MIPS score—a maximum of 100 points. Your score determines the payment adjustment you’ll get. For 2019, the maximum positive payment adjustment (incentive) is +7% while the maximum negative payment adjustment (reduction)is -7%.
The four performance categories are:
Quality: This encompasses the quality of care you deliver to your patients and it accounts for 45% of your final score. CMS has many performance measures and you must choose six that are best suited for your practice. You can find the performance measures here.The data you will submit in this category will be for the 12 month performance period, i.e January 1st to December 31st, and how much data you submit wholly depends on the performance measures you select.
Promoting Interoperability: This category is about the use of certified EHR for the exchange of health information either between clinicians or between clinician and patient. It accounts for 25% of your final score. You can explore the promoting interoperability measures here.
Improvement Activities: This category focuses on how you make your care processes better, encourage patient engagement and facilitate easier access to care. It accounts for 15% of your final score and you can take a look at some of the improvement activities that your practice can undertake here.
Cost: This places focus on how much the care you provide costs and makes up the remaining 15% of your final score. You actually do not have to submit any data in this category as CMS will use claims data from Medicare to calculate your performance here. There are 10 cost measures that you can be evaluated on, and you can explore them here.
As a physical therapist, you are required to participate in the Quality and Improvement Activities categories.
Q&A: What You Need to Know About MIPS Reporting and Participation
What are the participation requirements?
To participate in MIPS, your practice must use certified EHR Technologies (CEHRT). “All eligible clinicians, regardless of their specialty, must be using Certified EHR,” Kareo Sr. Training Specialist and MIPS expert Marina Verdara explains. “CEHRTs are EHR clinical software certified by the Office of the National Coordinator for Health Information Technology (ONC).”
If you aren’t already using a 2015 CEHRT and are seeing Medicare Part B patients, look towards migrating your practice onto a certified EHR platform as soon as possible.
Do I have to participate in MIPS?
As a physical therapist, you must meet all three of certain criteria called Low-Volume Threshold Criteria in order to participate in MIPS.
According to the Centers for Medicare & Medicaid Services (CMS), you are part of the MIPS track of the Quality Payment Program if you:
Bill more than $90,000 a year in allowed charges for covered professional services under the Medicare Physician Fee Schedule (PFS)
Furnish covered professional services to more than 200 Medicare beneficiaries a year.
Provide more than 200 covered professional services under the PFS
Once you meet these criteria, you are mandatorily subject to the -7/+7 payment adjustment for the performance year of 2019. However, if you only meet one or two of these criteria, you can choose to opt-in. This means that while you don’t have to, you can decide to join MIPS and make your practice subject to the payment adjustments.
Is there a submission period for MIPS reporting?
Yes, there is. All data for the performance year is to be submitted between January 1st to March 31st the following year. So for example, data from this performance year of 2019 will have to be submitted between January 1st, 2020 and March 31st, 2020. If you’re required to participate in MIPS and you miss the submission deadline, you’ll be subject to the negative payment adjustment.
If you’re required to participate but for some reason you did not meet all of the requirements, you can still avoid the negative payment adjustment.
“You’re going to get that negative payment adjustment if you don't submit any points at all. But if you submit the minimum points for the performance year—which is 30 points for 2019—you can avoid being penalized,” Verdara explains. “Instead, you’ll just fall into the neutral payment adjustment zone”
Dedication and planning are required for MIPS reporting.
“MIPS reporting is not simply a provider effort or a staff effort. This is a practice effort and everybody should be engaged,” Verdara advises. “You should form a team and that team should set goals and establish meetings—at least every two weeks—to review reports, to tackle those measures that need improvement and celebrate where the practice is doing well so that you keep that momentum going.”