The Pros and Cons of Opting into MIPS

I’ve spent an enormous amount of time researching MIPS—from digging through the 2,000-odd pages of the final rule and decoding line upon line of legalese, to participating in hour-long discussions (and dozens of email chains) with WebPT’s compliance experts. After all that researching, I feel pretty comfortable with the ins and outs of the program—as well as its benefits and drawbacks. So, let’s talk shop. Here are the pros and cons of MIPS participation:

Pros

MIPS isn’t all muck and mire—it actually has some pretty sweet draws for successful participants. So, CMS deserves some credit for trying to create a program that encourages high-quality care delivery across the health industry and throughout the entire patient experience—from treatment to cost.

MIPS provides monetary incentives.

One of the MIPS program’s biggest draws is its monetary incentives. If you (or your group) performs well under the MIPS program, you could earn a positive payment adjustment of up to 7% on all Medicare Part B claims during the payment year (which comes two years after the reporting year). And if you perform exceptionally well—like scored-more-than-75-overall-MIPS-points well—you could potentially earn another 10% in addition to the 7% adjustment. That adds up to a whopping 17% positive adjustment on every single Medicare claim over the course of the year.

And while it may be difficult to wrangle the full 17% adjustment out of CMS (more on that later), it’ll be pretty easy to stay in the positive (or at the very least, break even). The 2019 performance threshold is only 30 MIPS points out of a possible 100, so—as we illustrated with an example scenario during our MIPS webinar—you would have to bomb a category pretty badly to get saddled with a negative adjustment.

MIPS could increase the collection of vital data about the rehab therapy industry.

As WebPT President Heidi Jannenga, PT, DPT, ATC, frequently says, the best way to push the rehab therapy industry forward is to collect data and use it to demonstrate value. When rehab therapists participate in MIPS, they’re providing CMS with large-scale data that speaks to the patients they treat and the quality of care they provide. Eventually, this data could help objectively position rehab therapy as an effective—and often superior—treatment route for many chronic pain diagnoses. That data can then be used to improve rehab therapists’ reputation in the greater medical community—by pushing others to realize that therapy could be a solution to the opioid epidemic, for example.

MIPS encourages evidence-based treatment.

MIPS participants must report at least six quality measures—one of which must be an outcome measure (if available). Those who report additional outcome measures will earn bonus points—provided those measures meet the data completion standard, and the participant has met certain performance requirements. What does this tell us? CMS is placing a high priority on outcomes tracking—and I mean that pretty literally. Outcome measures are classified as “high-priority” measures.

Outcomes tracking inherently encourages evidence-based treatment (i.e., if you don’t see improvement in your patients, you will likely adjust their course of care—and apply that protocol to future, similar cases). And considering that evidence-based treatment is one of the pillars of the PT profession, MIPS seems to align with therapists’ overall goals and ethics. Plus, it could be an effective vehicle for encouraging the wider healthcare industry to adopt evidence-based practices and thus, improving the overall quality of patient care.

Cons

Though MIPS is a noble attempt to improve the healthcare industry on the part of CMS, the program is far from perfect. MIPS participation comes with some unfortunate realities that few people in the healthcare world are discussing—let alone addressing. So, let’s go down the road less travelled and unpack some of the hairier aspects of the MIPS program.

MIPS payouts probably won’t meet expectations.

That 17% positive adjustment I mentioned earlier sounded pretty good, right? Well, it’s nearly impossible for MIPS participants to secure that high of a payout—and that’s especially true for rehab therapists. Remember, MIPS is a budget-neutral program, which means that every positive payout will be funded by the negative adjustments incurred by poor performers.

Division of Payout

Because it’ll be pretty easy to meet the 2019 performance threshold (as I mentioned above), we can expect relatively few MIPS failures—and thus, a relatively small pool of money to distribute among successful participants. CMS reported that 93% of MIPS participants from 2016 earned a positive adjustment in 2018; as a result, the highest reported base adjustment was only 1.88%.

The lowest positive adjustment (and I’m not talking about the neutral adjustment) was 0.00%. In other words, some providers successfully reported MIPS and did everything they were supposed to, and they received either no adjustment, or an adjustment so small that CMS rounded it to zero. So, keep in mind that if you’re paying a vendor to help you report MIPS data and ensure compliance with the program rules, your performance bonus might not even cover the cost of participation.

Division of Exceptional Performance Bonus

Well, what about the exceptional performance bonus? Sorry to say, that’s divvied up from a flat $500 million pool. The more providers who earn that bonus, the lower the adjustment will be. And because CMS is creating more opportunities to opt in to MIPS and opening the program to more provider types, the exceptional performance payout will likely get smaller as the program ages.

MIPS is not geared toward rehab therapists.

I mentioned in the previous section that a large positive adjustment would be especially tough for rehab therapists to secure. As we wrote in our MIPS FAQ, “MIPS caters primarily to physicians.” Let’s dig into one example illustrating why that’s the case.

The Promoting Interoperability MIPS category was derived from Meaningful Use (MU): a program that never applied to rehab therapists. MU required participants to use Certified EHR Technology (CEHRT)—which is essentially an EMR that’s designed to share patient information between different practices. Because rehab therapists were excluded from MU, there are very few therapy-applicable software that classified as CEHRT.

MIPS offers bonus points to participants who use CEHRT, which ultimately means that many physicians will get those bonus points—and rehab therapists will not.

Lack of Quality Measures

When it comes to the quality category, rehab therapists—specifically SLPs—are facing a quality measure drought. There are 257 quality measures available for 2019 reporting; yet, only three of them apply to SLPs. Thus, participating SLPs have no choice but to report every single one of those measures—regardless of whether or not the measures apply to their scope of care.

MIPS reporting is often burdensome.

With its 2019 updates, CMS sought to reduce the burden of MIPS reporting—but there are some burdens it can’t quite erase. All program reporting comes with a little extra legwork—whether that’s recording quality actions to a degree you’re not accustomed to, or implementing a temporary 90-day policy that helps you check an improvement activity off your list.

The FOTO Issue

One of the largest 2019 MIPS reporting burdens for PTs and OTs is the program’s inclusion of Focus on Therapeutic Outcomes (FOTO) measures. As you might know, FOTO is a rehab therapy outcomes registry, and CMS has approved seven FOTO measures for inclusion in the PT and OT quality measure specialty sets. In fact, those are the only outcome measures available for these specialties. For those providers who have a FOTO membership, this is great news; you can complete your outcomes reporting digitally, and FOTO will send the data to CMS at the end of the year—easy peasy.

Those who are not FOTO subscribers, however, face significantly more burden. Here’s the process they must follow:

1. Go to the FOTO website, read the measure-reporting instructions, and download all applicable surveys, codebooks, and instructions.
2. Administer the FOTO surveys on paper and calculate the scores (including risk adjustment) by hand.
3. Record the risk-adjusted summary score in the visit note.
4. Use a designated spreadsheet to select the appropriate FOTO measure reporting code that indicates performance of the quality action.

That entire process is doable, yes, but consider the time it takes to complete those steps. Multiply that by multiple appointments, and remember that you’ll follow that process for multiple patients. And again, there’s no getting around the FOTO measures. PTs and OTs are required to report at least one outcome measure, and the FOTO measures are the only ones available.

MIPS is hard to understand, and it’s only going to get more complicated.

To few people’s surprise, MIPS is extremely complicated and pretty darn difficult to understand. We published this 5,000-word guide, hosted a 45-minute webinar, answered nearly 100 questions in our webinar FAQ, and created a MIPS participation quiz (in addition to tons of other blog content)—and we could still publish pages and pages of additional MIPS information.

And MIPS is only going to get more complicated. Right now, rehab therapists are only required to participate in the Quality and Improvement Activities categories, but there are two whole other categories (Promoting Interoperability and Cost) that therapists might have to consider in the coming years.

So, should you opt in to MIPS? That’s a question only you can answer, because you are the only one who can decide what’s right for you and your practice. That’s why it’s important to carefully weigh your personal pros and cons—and to consider the realities of MIPS participation.