MIPS Reporting Physical Therapy | Process + Data + Technology
Is MIPS reporting on your mind? With the CMS having recently released the proposed regulatory and payment changes for the 2022 performance year, it is likely that many physical therapy clinicians are thinking about it.
We are moving toward the end of the 2021 MIPS performance year. Rehab practices are perhaps busily collecting data for this year that will be reported by March 31, 2022, to be eligible for a positive payment adjustment and avoid a negative payment adjustment in 2023.
MIPS Reporting: A Quick Recap
A quick overview of MIPS just to level set. MIPS reporting is broken into four categories: Quality measures, improvement activities, promoting interoperability, and cost. A therapist?s MIPS performance scores factor in performance across two weighted performance categories: quality measures and improvement activities.
Here is a brief synopsis of the four categories:
The highest weightage is for the quality measures category, it is also where the biggest chunk of reporting originates.
Improvement activities refers to a list of activities that the physical therapy practice is attesting to as a group or as a clinic to improve the quality of care being delivered.
Promoting interoperability has to do with the technology being used. The EMR would need to be certified for certain measures and it would need to communicate with other technology solutions.
Cost is automatically calculated by the CMS after looking at utilization metrics.
The quality measures category is further broken into process measures and outcome measures. Process measures were carried forward from the erstwhile PQRS program. Outcome measures are a bit more complicated to report on. Foto is Practice Pro?s partner in reporting outcomes measures. There are two important metrics that underpin how we report physical therapy performance to the CMS.
Data completeness rate is the first. This is part of the MIPS performance report in Practice Pro. 60% of eligible encounters are needed to receive full credit for data completeness. Small practices (under 15 providers) have slightly different requirements. Below 60% data completeness will still earn full points.
The second metric is the performance rate. Of the measures that the clinic did complete, how many were completed positively and how many negatively. Measures in the Practice Pro system are designed to ensure that the performance rate calculation includes all positively completed measures and that no data is missed out.
In some scenarios, it may not be appropriate to report on some patients. If data completeness is healthy, we have seen that the performance rate will likely be healthy as well. The performance rate is also compared to historic benchmarks by assigning a points value based on what the performance rate is relative to the average benchmark. In Practice Pro, we have limited some of the selections to ensure that appropriate selections are made for the physical therapy industry. The performance rate is scaled based on historic benchmark data.
The next category is the improvement activities one. This lists group and clinic-wide activities that improve quality or access to care. The clinic would need to attest to having performed the activity for at least 90 consecutive days. When it comes to groups, at least one clinician would have had to participate in it. An example would be promoting the use of patient reported outcome tools. Documentation on procedures in the EMR would serve as additional detail. Collection and follow up on patient experience and patient satisfaction data would be another. A quick survey or NPS score would be an example.
MIPS Reporting: Diving into the EMR
The MIPS performance report in Practice Pro looks at the data completeness percentage:
Running the report generates data for the selected period. At a measure level, it provides an overview of how many eligible encounters there are and how many of those were completed.
Expanding the measure in the EMR shows how each individual therapist is performing for that measure.
The Practice Pro report is actionable as it enables therapists to probe deeper and make corrections. Clicking on the number of eligible providers navigates to a detailed view of the therapists? dates of services. Each measure has its own eligibility requirements. Most require an eval code. Some also require additional information like diagnosis and age range. The information could be sent to the therapist to confirm everything is in line.
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Over to Outcome measures. If the clinic is utilizing Foto measures but not properly discharging patients then outcome measures would be affected:
To successfully complete an outcome measure, at least two data points are necessary. Functional status scores at admission and at discharge.
The practice could capture these more frequently including scores at eval and at progress note stages as well.
Foto integration will pull these values from the EMR and produce a risk adjusted score. There is an option to exclude patients who drop off the schedule, stop showing up, or never get discharged.
Creating a quick discharge note with just one measure will work and bring up the reporting rate.
In Practice Pro, MIPS settings live in the administration menu. Under MIPS administration, users would select the reporting year, if Foto integration is being used to deliver outcomes, and the method of reporting. Selecting the group option would mean that every provider receives the same MIPS score. In the individual case, a separate submission would be made to the CMS for each individual provider. It would be needed to select the right providers for the year.
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Last but not least would be measure planning:
Selecting the measures being reported on and the applicable specialties for each measure.
Identifying any missing measures or providers in the performance report, when to sign off on documentation, and which measures will be enforced.
The correct setup will ensure healthy data completeness and performance rates. Foto outcome measures become complete only at the end of care.
The system will allow sign off on the evaluation encounter as long as you put in the admission score.
Discharging a patient that has started but an incomplete Foto outcome measure will result in a warning.
MIPS Reporting: Change In The Air
In the meantime, MIPS is shifting gears in the 2022 performance year. Here is a quick summary of key changes:
PTA and OTA payment cut that is softer than expected, netting to a 12% reduction.
Easing of rules for applying CQ and CO modifiers based on the extent to which PTAs and OTAs are involved.
2% cut to physical and occupational therapy payments and 1% cut to audiologists from reduction in the conversion factor.
Assigning all claims data associated with OT evaluation codes to the occupational therapy specialty ensuring CPT codes 97165-97167 receive the same indirect PE allocation.
No plans to extend telehealth privileges for rehab therapists beyond the active public health emergency.
Changed definition of direct supervision to allow the supervising therapist to be available virtually using real-time audio/video technology.
RPM codes (99453, 99454 and 99457) considered evaluation and management (E/M) codes, and therefore not billable by rehab therapists.
The MIPS program is making strides. Successfully leveraging the program does require instituting the right processes, data, and IT systems. Is MIPS reporting a priority for you this year?