Is MIPS Mandatory for You in 2021? Why You Should Double-Check Your Eligibility

This year has been one for the story books—full of unexpected twists and turns for the rehab therapy community, mostly due to the coronavirus pandemic. So, it should be no surprise that the pandemic has also thrown a wrench in providers’ 2021 Merit-Based Incentive Payment System (MIPS) eligibility status—specifically for those who have been required to report in the past. 

If MIPS participation was mandatory for you in 2019 and 2020, you’re probably assuming that you’ll be mandated again in 2021. But, given the past year’s circumstances, you may be surprised. Here’s why.

Business has not been “as usual.”

The pandemic completely upturned how rehab therapists delivered care and ran their businesses through 2020, and that, in turn, has substantially impacted patient volume. How does this affect  MIPS? 

The answer lies in the eligibility requirements. MIPS participation is mandatory for therapists who exceed all three low-volume threshold criteria:

• Billed Medicare for more than $90,000 in Part B allowed charges; 
• Provided care to more than 200 Medicare Part B beneficiaries; and
• Provided 200 or more covered professional services under the Medicare Physician Fee Schedule.

However, not meeting all three doesn’t mean participation is off the table. You always can voluntarily report—and you may be eligible to opt-in to MIPS if you exceed one or two of the threshold criteria. (For more on the nitty-gritty of MIPS participation, check out our full MIPS guide here.)

Given that the low-volume threshold hinges on the number of Medicare patients you treated during a set time frame—therefore affecting how many professional services you billed to Medicare during that period—there’s a good chance that disruptions to your clinic’s patient volume in 2020 impacted your eligibility status. And that means you may not be mandated to report in 2021—even if you were mandated in previous years. 

There are a lot of reasons to double-check your status.

If you experienced any of the following during the 2020 MIPS performance year, you may not have met all three low-volume threshold criteria required for mandatory participation in 2021:

• You were furloughed.
• Your clinic shut down.
• You shifted to virtual visits for a period of time.
• Your clinic experienced a significant dip in patient volume.

Luckily, checking your participation status is easy as cake. Simply navigate to the Quality Payment Program (QPP) participation status webpage, where you’ll enter your NPI and select the appropriate year. (CMS will release the 2021 lookup tool sometime in December 2020.) You really should check your participation status on a regular basis—especially given how easy it is to do so.

“Regardless of the current climate, checking your MIPS status regularly is a habit you’d be wise to adopt moving forward,” says Dr. Dianne Jewell, WebPT’s director of clinical practice, outcomes, and education (and our resident MIPS expert). “The MIPS payment model is the way of the future, and whether or not it’s mandatory for you right now, it’s something every rehab therapist will eventually need to get comfortable with.”

If you’re not mandated to report in 2021, you’ve got options.

Say your status does change, and you’re no longer required to participate in MIPS in the coming year. In this case, you have three options:

• Do nothing, and assume no risk or reward;
• Continue collecting data and submit voluntarily; or
• Opt-in to the program if you still meet one or two of the low-volume threshold criteria. (Remember, choosing this path means you agree to accept the same financial risk or reward that a mandated therapist experiences.)

So, what should you do? That depends on how confident you are in your performance this past year. We covered how to calculate your MIPS return on investment in this blog post, and it can help you determine whether participation may help or harm your clinic in the upcoming year. What’s more, a high MIPS score in 2021 could translate into a bonus that helps your practice recoup some revenue lost this past year. The only catch? You won’t see your ROI until 2023, per the program’s payment adjustment structure.

If you struggled with MIPS reporting in 2020, you have an “out.”

To this point, we’ve been talking about the future. But, what can you do now if you were mandated to participate in MIPS in 2020, but were unable to see patients or collect data for an extended period of time? Fortunately, there’s a relief option for you.

CMS recognizes that COVID-19 has caused business interruption, so the agency will cover pandemic-related hardship under its Extreme and Uncontrollable Circumstances Application for MIPS participants. Through this application, participants can “request reweighting of one or more MIPS performance categories to 0%” due to hardship from extreme and uncontrollable circumstances—such as a global pandemic.

Because PTs, OTs, and SLPs are currently only eligible to participate in two of the four MIPS categories (quality and improvement activities), they can ask CMS to reweight one or both of these categories. Check out this blog post to learn more about the application process. 

“The beauty of this application is that it’s a great safety net for those who shut down, shifted to telehealth, or experienced a dip in patient volume this past year,” adds Dr. Jewell. “What’s more, if a therapist finds that they’re on course to secure a great MIPS score, the exception will be waived at no cost to them if they submit their quality measure and improvement activity data to CMS by March 31, 2021.”

Applications are due on December 31, 2020, and are reviewed on a case-by-case basis.

Although we can’t always foresee “extreme and uncontrollable circumstances,” there are a few things rehab therapists can do to protect themselves if and when they occur—like checking their MIPS status and taking advantage of safeguards created to help them avoid unnecessary penalties after an already-difficult year. 

Need more help demystifying MIPS 2021? Drop your questions below, and we’ll do our best to answer them.