MIPS Reporting Physical Therapy 2022 | Do More Or Less Or Nothing!

We are in the middle of the 2022 MIPS Performance Year. With the CMS having extended the access to its Extreme and Uncontrollable Circumstances Application for MIPS participants in 2022, PTs have had the option to opt out even if they were required to take part in MIPS. Through this application, they could request reweighting of the MIPS performance categories to 0%. If their application were to be approved by CMS, they would face no penalties in the 2024 payment year for not reporting.

There has also been the option to simply do nothing!

But should therapists participate? There might be a few reasons why they probably should despite the options to opt out and avoid MIPS reporting altogether.

  • MIPS represents the first step on the long overdue transition to value based care where providers are paid for delivering value instead of volume of services. Value based care aligns with the desire of therapists to do good for patients instead of just running on the “more services treadmill.”
  • The MIPS award, small though it may be, likely represents the only way to get an increase in payment rates from the CMS in the future. Without MIPS reporting, clinicians have to be content with a flat, 0% increase even as inflation increases costs all around them!

MIPS Reporting: A Quick Recap

Here is a quick overview of MIPS just to level set. MIPS reporting is broken into four categories: Quality measures, improvement activities, promoting interoperability, and cost. Just two of the four categories namely quality measures and improvement activities count for physical therapists.

PTs that meet all three below criteria during both determination periods are required to report in MIPS:

  • Bill Medicare for more than $90,000 in Part B allowed charges.
  • Provide care to more than 200 Medicare Part B beneficiaries.
  • Deliver more than 200 covered professional services under the Physician Fee Schedule.

Those PTs who meet one or two of the above criteria can opt in and participate in the risks and rewards of the program. Those who meet none of the criteria can still choose to participate in a kind of “observer status” receiving no rewards and facing no risks either.

Only individual therapists are required to participate in the program. But eligible therapists in a practice (under the same tax id number) can band together to report as a group and then it is the group that is evaluated for potential rewards or penalties in the payment year, with all members of the group getting the same score.

The potential reward/penalty is on a sliding scale from 0% to +/-9%. But actual rewards have not exceeded 2% in the past. With MIPS being a budget neutral program, penalties fund the rewards payout.

Challenges Holding MIPS Back

In the PT world, there have been a number of challenges that have reduced the participation rate from practices as we have seen.

  • With the Covid19 emergency waivers, it effectively became optional and anyone could opt out even if they were statutorily required to participate.
  • As actual rewards have been minimal, around 2% and lower, the financial incentive to take part has been weak whereas the risk of penalties have been non zero.
  • Participation and data submission represent a digression from busy schedules and create an administrative burden, taking time away from treating patients to look at data completion.
  • Being a program for individual therapists and not practices, there has been a complex dynamic of how and to what extent clinics should support their therapists in responding to MIPS.

An Alternate MIPS Future

Now let us step back and imagine a different future for MIPS in the years ahead.

  • All pandemic waivers are withdrawn and everyone is required to participate if they meet the threshold for participation.
  • The reward pool is increased and external funds are allocated to reward performing therapists, effectively raising payouts to well over 2%, maybe 5-6-7% whatever.
  • The CMS lays out a detailed plan of how the march to full value based care and capitated payments will unfold, making it clear that value based care will be an absolute reality.
  • Commercial payers join the bandwagon, adopt a version of MIPS for their own payments, and start rewarding or penalizing participants for outcomes.

In this alternate world, the case for participation should become much more compelling as by opting out, therapists would:

  • Forgo substantive rewards that would be invaluable in a remuneration challenged world.
  • Miss out on the training and practice to prepare for an inevitable transition to value based care.

The alternative is more of the fee for service model that we are in, which is in conflict with being patient centered and outcomes driven, and really does not help either patients or payers. Therefore we should expect that the MIPS program (or something similar) could only get strengthened in the years ahead. More MIPS in the future is what we should expect. For rehab therapists and other healthcare providers, it should translate to “less is more.”