It has been quite a busy year! Although this column is not intended to exhaustively cover all rules and regulations, let’s look back at what we learned this year about the Quality Payment Program (QPP) and other documentation approaches to plan ahead using smart strategies. And remember, it is your responsibility to understand the rules and regulations that govern your business while mapping the coding and coverage guidelines into your practice as appropriate.
QPP and Your Workflow
The CMS is required by law to implement a quality payment incentive program that rewards value and outcomes via the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models. Clinicians are included in MIPS if they are an eligible clinician type and meet the low-volume threshold. Beginning in payment year 2019, the low-volume threshold encompassed allowed charges, the number of beneficiaries who receive services, and the number of services provided. Clinicians must participate in MIPS (unless otherwise exempt) if, in the determination period, they bill more than $90,000 for Part B-covered professional services, see more than 200 Part B patients, and provide 200 or more covered professional services to Part B patients.
The Eligible Clinician Type list that must report this year has expanded to include physical therapists, occupational therapists, clinical psychologists, qualified speech-language pathologists, qualified audiologists, and registered dietitians or nutrition professionals. To determine participation status, use the QPP Participation Status Tool and ensure you review your eligibility data at multiple points throughout the year to help you plan your program participation. Remember, if you are eligible and do not score at least 30 points, you can lose up to 7% of your Medicare fee reimbursement to your 2021 payments.
Next, ensure you understand the configuration of your workflow and verify you have incorporated all documentation requirements. Check your MIPS documentation progress often to verify documentation requirements are being met. Last, remember that change in process always brings an opportunity to review and refine documentation workflow(s) in general. Note: The submission window for reporting payment year 2019 opens January 2, 2020, and closes March 31, 2020.
Read previous articles in “Advances in Skin & Wound Care” by Cathy Thomas Hess in the link.
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Cathy is Chief Clinical Officer for WoundExpert® and Vice President at Net Health, and in addition to being the MIPS Clinical Consultant for WoundExpert. She gained over 30 years of expertise in various acute care, long-term care, sub-acute care facilities, home-health agencies, and outpatient wound care department settings. Cathy is the author of Clinical Guide to Skin and Wound Care (also translated into Italian and Portuguese) – Eighth Edition published in September of 2018.