Founder Letter: Reconsidering MIPS: Should PTs Participate in 2020?

Over the past year or so, the idea of MIPS participation has undergone an enormous transformation in the minds of rehab therapists. When the program was first introduced, we were optimistic about participation, and we heralded its arrival as an opportunity for therapists to prove their worth to CMS. But, as time passed and more details about the program came to light, our perception of MIPS morphed and twisted until it looked like a big, bad, kind-of-scary boogie monster—like the one that used to hide under your bed when you were a kid. MIPS was (and in some ways, still is) a big shadowy unknown:

• The program was—and is—difficult to understand;
• Many companies have used the widespread MIPS-related confusion as a vehicle for fear-mongering; and
• In years past, the burden of participation often outweighed the benefits of opting in.

Unfortunately, with the looming industry-wide cuts to Medicare payments, therapists may no longer have the luxury of pushing MIPS back to a dusty corner under the bed. It’s looking increasingly likely that 2020 may be the year that rehab therapists have to shine the light of our attention directly on the MIPS monster—and face the program head-on.

What did MIPS reporting look like in 2019?

Last year was rehab therapists’ inaugural MIPS inclusion year, and those who were required—or chose—to participate were tasked with navigating a myriad of complicated rules and requirements. For instance, you could perfectly satisfy all MIPS reporting requirements, but if you submitted your data late (keeping in mind that the definition of “late” varied depending on your submission method), then all your data would go down the drain. Didn’t correctly adjust your reporting to account for a topped-out measure? There went some of your MIPS points. Forgot to attest to your completed improvement activities? Tough. CMS is more than willing to dock points from your final score.

2019 Performance Threshold

Needless to say, navigating the MIPS minefield could get a little treacherous—especially because failure came with a potentially steep price. A therapist who failed to meet the minimum performance threshold of 30 points would receive a negative payment adjustment of up to 7% on all Medicare payments two years in the future. Conversely, a therapist who exceeded that 30-point threshold would receive a positive payment adjustment up to 7%. Therapists who exceeded a secondary threshold of 75 points would receive an additional positive payment adjustment of up to 10%. However, all positive payment adjustments are (and will continue to be) limited by MIPS’s neutral budget plan—so, the actual incentive payments therapists see vary based on how many participants failed, met, and exceeded the two performance thresholds. In other words, nothing is guaranteed.

2019 Required Categories

In 2019, rehab therapists were only required to participate in two of MIPS’s four categories: quality and improvement activities. Quality, the most complicated category, involved reporting measures based on a therapist’s billed CPT codes (i.e., did you complete a specific task when you billed a certain CPT code under a certain set of circumstances?). At the end of the day, PTs, OTs, and SLPs could choose to report from a selection of 15, 16, and three measures, respectively.

The improvement activities category was a little bit easier to complete—but, for most outpatient therapists, it was a totally new concept. It required therapists to perform various tasks that would improve the quality of care in their practice across a 90-day time frame. The scope of these tasks varied from administering patient surveys or using a QCDR, to encouraging patient outcomes monitoring.

What will MIPS reporting look like in 2020?

As was expected, CMS implemented some updates to the MIPS program for the 2020 performance year. Namely, it raised the thresholds—thus tightening the margin for error—and bumped up the potential rewards and penalties of participation. CMS raised the performance threshold from 30 to 45 points and bumped the secondary performance threshold for exceptional performance from 75 to 85 points. Those who don’t surpass the base performance threshold of 45 points could see a downward adjustment as steep as 9%—but those who score more than 45 points could earn as much as a 9% bump to their Medicare payments in 2022.

Rehab therapists will still only have to report for the quality and improvement activities categories, but successfully doing so will be a little bit harder. Quality measures must be reported more frequently, and, for those who opt into group reporting (as more than half of WebPT’s MIPS participants are expected to do), more clinicians will have to physically complete the group’s selected improvement activities. Furthermore, CMS added a handful of net new quality measures for PTs, OTs, and SLPs to report, and it removed, modified, or added a total of 24 different improvement activities.

How will this year’s MIPS changes affect rehab therapists?

Essentially, these changes all boil down to one concept: higher risk, higher reward. While CMS hasn’t made MIPS participation ridiculously difficult, it will still be harder to meet the reporting criteria this year compared to previous years. And remember, it’s not all about upside: participating therapists will need to submit more data and perform better than ever before in order to avoid a downward payment adjustment that can fall as low as 9%.

However, it’s important to keep in mind that there are two sides of this coin. MIPS remains a budget-neutral program, which means the positive adjustments that successful providers earn come directly from the pockets of the providers who fail to perform. Because it will be more difficult to successfully participate in MIPS in 2020, there will likely be more abject failures—which means that payment bonuses might see a slight bump.

Is this your ticket to recouping some of the revenue lost to the impending 8% and 15% cuts?

CMS hit the rehab therapy industry with a double whammy this year. Not only will PTAs and OTAs see a 15% payment reduction on the services they provide independent of a therapist in 2022, but the industry as a whole will also see a sweeping Medicare payment cut in 2021 that CMS is predicting will total around 8%. This could have some serious financial implications for many clinics—especially those with a large Medicare population.

But, if you participate in MIPS and perform well, you have a chance to recoup some of your lost revenue. Remember, the 15% PTA and OTA reduction will take effect in 2022—the same year that 2020 MIPS participants will receive their performance adjustments. Unfortunately, the 8% payment cut will occur in 2021 (one year before the 2020 payment year) so this solution is not perfect—but it’s better than nothing.

Balancing Act

Now, before you rush out and sign up for MIPS, please understand that I’m not casting MIPS as a revenue-balancing guarantee. As I mentioned previously, opting into MIPS is a risk-reward kind of deal—and in previous years, the reward hasn’t exactly been awe-inspiring. CMS has released one year of MIPS performance results (for 2017), and it revealed that the highest incentive payout was a modest 1.88% increase—and that included the boost from the exceptional performance bonus. This is a far cry from the 15% and 8% cuts that Medicare is hurling our way, but again, it’s something—and I do predict that there might be a slight increase to the average positive MIPS payment adjustment in the coming years.

My thought is that this may be a way for therapists to make up for the steady stream of downward adjustments that we can’t seem to escape. However, I want to emphasize that MIPS isn’t an added revenue guarantee, and some practices might still be better off avoiding the program altogether. For example, 94% of the TINS that participated in MIPS through WebPT in 2019 were small practices—for which reporting can be more burdensome. That’s why it’s absolutely crucial that you do your due diligence and really weigh the pros and cons of MIPS participation in your specific organization.

WebPT and MIPS

If you do decide to participate in MIPS, you don’t have to do it alone. We’re dedicated to ensuring our Members’ success in this program, which is exactly why we teamed up with a QCDR (Healthmonix) to submit five quality outcomes measures to CMS for inclusion in the 2020 measures set—all of which were approved and will be available next year. In other words, our Members will no longer have to submit FOTO measures to complete the quality category; instead they can report the outcome measures that are bundled in with WebPT’s MIPS solution. And while it’s difficult for us to predict our Members’ final 2019 MIPS scores (there is still another month left in the year, after all), the TINs that have already attested to their improvement activities are projected to exceed the neutral payment threshold.

Rehab therapists are at a critical juncture. Medicare payments are steadily trending downward, and each of us has to make a decision: is it better to travel down the path of least resistance and try to shoulder CMS’s cuts—or face the MIPS monster head-on and try to take back some of the revenue lost? It’s a tough call to make, and only you know the right decision for your practice. I wish you luck—and please remember that WebPT will be in your corner to lend a helping hand and provide any education you need to succeed.