5 MIPS Lies You've Been Told—But Should Not Believe

WebPT is a purpose-driven company that’s gained the trust of its Members by prioritizing integrity, which, by definition, requires honesty and strong principles. As a company executive—and also as a consumer—I know that being lied to is the worst, especially when a person or company does it in order to benefit at my expense.

Unfortunately, there seems to be a lot of this going on in our industry right now when it comes to Medicare's Merit-Based Incentive Payment System (MIPS). That is, there are technology companies in our market that are spreading misleading information about Medicare’s newest reporting program with the sole objective of convincing providers to purchase their products and use their services. In other words, they’re flat-out lying to make more money—or, they’re so uninformed on basic compliance requirements that they shouldn’t be trusted to be in this business in the first place. Either way, I’m putting my foot down. It’s one thing to honestly tout your company’s benefits; we all know I’m a huge proponent of effectively selling your value, but that’s with integrity. It’s another thing entirely to manufacture benefits through fear-mongering.

With that in mind, here are five MIPS lies you may have been told—but most certainly should not believe (and beyond that, you may want to question the source’s integrity):

Lie #1: You'll probably be required to report.

In fact, the exact opposite is actually true: the APTA estimates that only 10% of PTs will meet the 2019 criteria for mandatory MIPS participation. That means the vast majority of providers won’t be required to participate in MIPS this year—and many won’t be eligible to participate at all. So, before you go changing all of your clinic’s processes and switch software vendors for a specific MIPS solution, be sure you and your staff members even need it by checking your eligibility status here.

And if you’re not required to participate, you’d be wise to consider the potential downfalls of optional participation, too. MIPS is a budget-neutral program, which means the size of the incentive payouts is wholly dependent on the penalties collected from participants who perform poorly. And speaking of performing poorly, keep in mind that if you choose to opt in, you’re putting yourself at risk of incurring a downward adjustment. So, it’s not just about the potential upside.

Lie #2: Even if you're not required to report, you should opt in for your chance at a 7% bonus.

While a 7% bonus may sound good, because of therapists’ unique reporting limitations—and the highly complex scoring system—it’s highly unlikely that high-performing therapy providers will earn the full incentive amount. And again, because of the budget-neutral nature of the MIPS program, the only guarantee you have at this point is that, if you perform well, you’ll get a positive payment adjustment greater than 0% (vague much?). All this uncertainty makes it impossible to conduct an accurate return on investment (ROI) analysis. After all, an incentive that small may not be worth the effort you put in—or the amount you pay a vendor—to collect and submit your data. (I know some companies are also offering incentive “guarantees.” To that, I’ll just respond with the old adage: “If it sounds too good to be true, then it probably is.” When the data is not substantive enough to make a decision, go with your gut.)

Lie #3: You must submit MIPS data using a QCDR.

Nope; if you are required to participate—or if you choose to voluntarily report—you can submit your data using a Qualified Clinical Data Registry (QCDR), but you don’t have to. You can absolutely comply with MIPS reporting requirements with a certified registry like WebPT’s. Plus, our submission process is automatic and our quality reporting is built into our documentation, whereas use of a QCDR typically involves double data-entry. In other words, when it comes to submission method, it’s your choice. Don’t let anyone else make it for you.

Lie #4: You need a patient engagement or patient relationship management (PRM) platform to complete MIPS.

First, you do not need a patient engagement or PRM platform to complete the MIPS Improvement Activities requirements; using PRM software is just one potential activity among dozens of other options. Second, some software vendors are strong-arming their customers into purchasing PRM simply because those companies have chosen to offer their MIPS reporting functionality via their PRM—rather than their EMR. Talk about doing what's best for the company—not the customer. If you completed PQRS through your EMR, you should be able to complete MIPS within your EMR as well. Furthermore, at its core, PRM is a marketing tool—and why would you need (or trust) a marketing tool to ensure your compliance with a clinical-focused quality data reporting program? Not only does that not make any sense, but it also feels downright scammy.

Lie #5: Eventually you'll be required to report, so you might as well start now.

I’ve been a staunch proponent of contributing to industry-wide data collection efforts, but the ambiguity around MIPS has put me in watch-and-learn mode. Maybe you’ll be required to report in the future; maybe not. Maybe the MIPS program will endure as a pillar of the transition to value-based care delivery; maybe not.

We’ve all seen what’s happened to Medicare’s previous reporting programs (hello, PQRS and FLR). And even if you end up having to report at some point, why not sit back and use this year to see what happens with the program—and the bonuses—so you can make a more informed choice regarding participation going forward? Plus, it is highly unlikely that across-the-board mandated participation would happen by next year, because that would be a logistical nightmare for CMS. And even if it does happen, the question remains: is the juice worth the squeeze? In other words, are the potential benefits worth your effort? As of now, I say, “No way.”

The bottom line is this: most of you reading this right now won’t be required to report based on the low-threshold criteria established by CMS. If that’s the case for you—and you’re still planning to report—I behoove you to ask yourselves why. Are your reasons valid—or are they based on manipulative tactics employed by unethical companies that are exploiting your fears and trying to sell you a service you don’t really need? Are you making an educated decision based on facts and logic—or are you making it out of anxiety and distress?

This doesn’t mean I’m anti-MIPS—and WebPT fully supports those providers who choose to participate with a top-notch reporting tool. After all, some of you may benefit from opting in—and there are potential benefits to this type of wide-scale data collection. (Although, based on the low-value measures CMS has provided for rehab therapists, I’m much less inclined to believe our participation at this juncture is going to benefit our industry at scale.) I just want to see providers making conscious, well-educated decisions to participate—not being manipulated by greedy, short-sighted companies that put profit above people.

And for those of you who do participate in MIPS this year—or any year—please choose your reporting partners wisely. Any company that uses questionable tactics to push you into a purchase isn’t going to be a long-term partner for your practice. They’ve already betrayed you once; they’ll do it again. Actually, that advice stands whether you participate in MIPS or not. If you’re currently using software from a company that’s exhibiting this type of behavior, I would think long and hard about what else they might be lying to you about. After all, it’s a huge reflection of that vendor’s integrity—and integrity should be a must-have for any company you choose to do business with.