MIPS FAQ for PTs, OTs, and SLPs

Introduction

Unless you’ve been intentionally avoiding all discussions of healthcare changes for 2017, you’ve probably heard at least mention of CMS’s Merit-Based Incentive Payment System (MIPS), which consolidates aspects of the Meaningful Use (MU), Physician Quality Reporting System (PQRS), and Value-Based Payment Modifier (VM) programs. While MIPS went into effect on January 1, 2017, physical therapists (PTs), occupational therapists (OTs), and speech-language pathologists (SLPs) aren’t eligible to participate until at least 2019. And we’re all still waiting on further direction from CMS as to how rehab therapists can voluntarily report in the interim. In the meantime, though, we thought we’d take some time to go through the most frequently asked MIPS questions—as well as their answers. That way, you’ll be ready whenever it’s go-time. Read on to learn more (or click one of the links below to go to a specific question)

What is MIPS?

As mentioned above, the Merit-Based Incentive Payment System (MIPS) is a consolidation of Medicare’s Meaningful Use program (MU), Physician Quality Reporting System (PQRS), and Value-Based Payment Modifier (VM) program. It officially went into effect on January 1, 2017 (with payment adjustments affecting Medicare Part B payments beginning in 2019). According to this CMS site, 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”:

1. Quality (Replaces PQRS)
2. Improvement Activities (New)
3. Advancing Care Information (Replaces MU)
4. Cost (Replaces VM)

According to this SA Ignite resource, these categories are weighted to make up to 100 percentage points:

• Quality: 60% for 2017
• Improvement Activities: 15% for 2017
• Advancing Care Information: 25% for 2017
• Cost: 0% for 2017, but cost will be weighted in 2018 and beyond

A provider’s final score then 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). Under MIPS, eligible providers have the option to participate individually or as a group under one Tax ID—and, according to this American Academy of Family Physicians (AAFP) document, “if you choose to report as a group, you must report as a group across all four MIPS performance categories.”

Are rehab therapists eligible to participate in MIPS?

While therapists weren’t considered “eligible professionals” (EPs) under Meaningful Use, they are EPs under MIPS—and its umbrella program, the Medicare Access and CHIP Reauthorization ACT (MACRA). That being said, rehab therapists aren’t required to submit MIPS data until at least 2019. While CMS has indicated that providers such as rehab therapists will be able to voluntarily participate in the interim—and we strongly believe they should—the agency has not yet provided any additional details as to how those providers should go about doing so. In the meantime, WebPT’s president, Heidi Jannenga, recommends therapists “continue building our data stores by committing to collecting meaningful outcomes data.” (Please note that MIPS applies only to eligible providers who bill for Medicare Part B or Critical Access Hospitals that use Method II payments.)

Is PQRS really dead? What about FLR?

As of January 1, 2017, CMS has discontinued the Physician Quality Reporting System (PQRS); however, functional limitation reporting (FLR) remains in effect. As a note, eligible providers who didn’t meet PQRS requirements for 2015 or 2016 are still liable for the penalty in 2017 or 2018, respectively. To learn more about the difference between FLR and PQRS, check out this post.

What does MIPS reporting entail?

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 and fulfill the required advancing care information measures. However, according to the AAFP, to “ease the transition to MIPS, CMS has introduced the Pick Your Pace option for the 2017 performance period.” That means 2017 EPs can choose to participate on a full, partial, or test basis to avoid incurring a negative payment adjustment (the reporting requirements and associated incentives vary for each level of participation). Stay tuned to the WebPT Blog for more specific program instructions as we learn how therapists can voluntarily participate in the program. Or, check out this CMS chart to learn what other providers must do to satisfy MIPS requirements in 2017.

If I met PQRS requirements, will I automatically meet MIPS requirements?

Nope. According to the above-cited SA Ignite resource, “Although MIPS inherits much from the MU, PQRS, and VBM programs, historical high performance or penalty avoidance under the existing programs does not guarantee the same under MIPS.”

What are the financial implications of MIPS?

Per the same resource, under MIPS, eligible providers are subject to:

• A small annual adjustment to the Part B fee schedule (+.5% through 2019; then +.25% in 2026 and beyond).
• A value-based payment adjustment—positive or negative—based on the provider’s final score.

Each year, CMS will establish a performance threshold—the number of points providers must earn in order to remain neutral (i.e., receive a 0% payment adjustment). For every point above the threshold, that provider will earn an incentive; for every point below, the provider will incur a penalty (up until a set maximum is reached). Providers also will have the opportunity to earn an exceptional performance bonus if they earn an exceptional number of MIPS points. According to the same resource, beginning in 2019—the earliest that PTs, OTs, and SLPs will be eligible to join in—the performance threshold will be set annually based on the average MIPS scores of all eligible providers during a previous period (as determined by CMS).

What are the reputation implications of MIPS?

Apparently, CMS will release each participating provider’s annual final score—and the scores for each MIPS performance category—to the public. Per the SA Ignite document, this will be the first time that “consumers will be able to see their clinicians rated on a scale of 0 to 100 and how their clinicians compare to peers nationally.” And in case you were hoping you’d be able to start fresh every time you switch jobs, think again: “CMS binds the MIPS score to the clinical for each performance year.” That means that if a provider changes jobs before the performance year, he or she “brings along her or her MIPS score and the associated Part B payment adjustments to the new organization.” As you can imagine, this could seriously affect hiring (among other things like “recruiting, credentialing, contracting, and compensation plans.”). As the authors of that resource point out, “Each MIPS score thereby becomes a central and inextricably part of a clinician's profile and public reputation for the succeeding two years after that score is earned.”

How will MIPS adoption impact technology use?

As I discussed in this post, unlike MU—which required all eligible professionals to use a Meaningful Use-certified EHR—“MIPS is taking the focus off of the technology itself and placing it on the outcomes clinicians are able to achieve through the use of technology.” According to Anil Jain, MD, FACP, and Karen Handmaker, MPP—the authors of this Becker’s Healthcare article—“Through MACRA, CMS appears to be placing more emphasis on delivering better outcomes rather than on driving technology adoption, aligning to those stakeholders who have long embraced the move from traditional fee-for-service to value-based care initiatives.” Thus, “while physical therapists still don’t need an EHR certified for MU, they absolutely must implement a software system that enables them to measure meaningful outcomes—and use the data they collect to communicate the effects of their therapeutic interventions.”

Why should therapists voluntarily participate in MIPS?

As WebPT’s Brooke Andrus and Charlotte Bohnett explain in this post, voluntary participation in MIPS could be a game changer, especially if enough providers participate. That’s because:

1. “It allows therapists a chance to maintain continuity in their quality data-reporting habits.
2. “It provides therapists with a no-pressure opportunity to learn the ins and outs of MIPS reporting—without the threat of a negative payment adjustment hanging over their heads.
3. “It gives therapists the benefit of entering the third reporting year—during which they will, as CMS has suggested, be considered eligible providers—feeling much more confident than their physician colleagues, who do not have the option of voluntary participation right off the bat.”

Additionally, in the final rule, CMS stated that it has every intention of providing voluntary participants with feedback on their MIPS performance. While we’re still waiting to hear what, exactly, this will entail, knowing how you’re doing—before you have the added pressure of a payment adjustment—could serve as a serious leg up.

Will MIPS reporting be built into the WebPT application?

WebPT will definitely have built-in MIPS functionality once this program becomes a requirement for PTs, OTs, and SLPs (currently, that’ll be in 2019). In the meantime, while CMS has indicated that it will allow non-eligible professionals—including rehab therapists—to participate in MIPS on a voluntary basis this year and next, the agency still has not issued clear guidelines on how providers should go about submitting their data. We are continuing to work with CMS to get more specific guidelines around voluntary participation—and we’ll keep you posted with more information as soon as it becomes available.

There you go: The rehab therapy community’s most frequently asked MIPS questions—and their answers. Have MIPS questions that we haven’t already addressed? Leave them for us in the comment section below, and we’ll do our best to get you the answer.