What is MIPS?
MIPS stands for Merit-based Incentive Payment System. Quite simply, it is Medicares newest implementation of an all-in-one, pay-for-performance program. What were previously separate programs (PQRS, Meaningful Use, VBM) have been combined to form a single MIPS score.
Is MIPS mandatory for me or my therapy practice?
MIPS is not technically mandatory for any individual or practice, however, similar to PQRS, it can affect your Medicare reimbursement in the years following (up to +/- 9%). That is a pretty significant number for most practices, but if you fall below one or more of these low-volume thresholds, you will not be required to participate:
- ? $90,000 in Part B allowed charges
- ? 200 unique Part B beneficiaries
- ? 200 covered Part B professional services
How do I participate in MIPS?
Similar to PQRS, there are a few ways to participate, mainly claims based reporting (submitting CPT codes) and registry reporting (vendor submits on your behalf). For the 2019 reporting year, claims-based reporting is only available to small practices (defined as 15 or fewer clinicians). While many of you fall under this category, the far better option is registry reporting.
We are proud to announce that Practice Pro will be a 2019 CMS Qualified Registry (official announcement in early November)! This means that you will be able to participate in MIPS directly through our EMR module as a part of your normal clinical documentation process!
Great! So, for PTs and OTs what measures do we report on?
As I mentioned above, MIPS is technically broken into 4 overarching performance categories: Quality, Promoting Interoperability, Improvement Activities and Cost. For PTs and OTs participating in the 2019 reporting period, only 2 of 4 categories will be required.
This category replaces the PQRS program. You will find that almost all the measures available to PTs and OTs are identical to previous PQRS yearsthats a good thing, because you should already be familiar with them! Here are the measures that will be supported through the Practice Pro registry:
- Measure 126: Diabetes Mellitus: Diabetic Foot and Ankle Care
- Measure 127: Diabetes Mellitus: Diabetic Foot and Ankle Care, Ulcer Prevention
- Measure 128: Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan
- Measure 130: Documentation of Current Medications in the Medical Record (High Priority)
- Measure 131: Pain Assessment and Follow-Up (High Priority)
- Measure 134: Preventive Care and Screening: Screening for Depression and Follow-Up Plan
- Measure 154: Falls: Risk Assessment (High Priority)**
- Measure 155: Falls: Plan of Care (High Priority)**
- Measure 180: Rheumatoid Arthritis (RA): Glucocorticoid Management
- Measure 181: Elder Maltreatment Screen and Follow-Up Plan (High Priority)
- Measure 182: Functional Outcome Assessment (High Priority)
- Measure 226: Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention
Promoting Interoperability (NOT REQUIRED):
This category replaces the program previously referred to as Meaningful Use. This was a program that rewarded the use of compliant, meaningful health technology solutions (mainly certified EHR software). In the past, PTs and OTs were not eligible for this program so there was no incentive to adopt EHR systems. As such, CMS has determined that for the 2019 reporting period, there are not enough measures available for therapists to meaningfully participate in this category.
Improvement Activities (REQUIRED):
This is a new category designed to reward (or penalize) practices for actively improving care processes. A list of over 100 activities will be available in the Practice Pro system to select from, sub-categories including things like improving patient accessibility, engagement and safety (you can access the full list of activities on the official CMS site). To receive full credit for this category, your practice will need to attest to implementing these improvements for at least 90 days with one of the combinations below:
- 2 high-weighted activities
- 1 high-weighted activity and 2 medium-weighted activities
- At least 4 medium-weighted activities
Cost (NOT REQUIRED):
This performance category replaces the previous Value-Based Payment Modifier (VBM) program. Technically, there is no data submission or attestation required for thisdata is automatically collected from claims submitted to Medicare. At any rate, CMS is proposing a 0% weight in this category for PTs and OTs in the 2019 reporting period.
How can we start preparing?
Educate yourself and your team! We will be producing more articles like this as the details become finalized sometime in November, but in the meantime, CMS has some great tools and resources on their Quality Payment Program website:
Check your participation status (by NPI)