August 25, 2022 | Net Health

5 min read

MIPS Value Pathways: The Good, the Bad, and How FOTO is Ready with MVPs for Rehab Therapists

If as a rehab therapist you find MIPS to be confusing, we have both good news and bad news to share … and then a little more good news.

First, the good news.

The Centers for Medicare and Medicaid Services (CMS) has developed subsets of measures and activities called MIPS Value Pathways – MVPs for short – that are meant to help reduce some of the confusion providers experience with MIPS.

These MVPs have been slow to develop thus far, which is the bad news.

Just seven new value pathways have been added this year1, and only five more MVPs will be considered for the 2023 performance year2. None of them directly establish new pathways for physical therapy or occupational therapy.

However – and this is the silver lining for rehab therapists – FOTO® has your back.

Since CMS began to accept MVP candidates (CMS lingo for new rule submissions) back in 2021, FOTO® has remained active in developing and submitting physical therapy- and occupational therapy-specific MIPS Value Pathways to CMS each year.

This is a lot to take in within a few short paragraphs. So, let’s break this down a little more, starting with the basic question, “What’s an MVP?”

What Are MIPS Value Pathways?

To understand MIPS Value Pathways, it’s important you first understand MIPS.

Click to read “MIPS 101: Learn the Basics of CMS’s Merit-Based Payment System

MIPS is an acronym for Merit-Based Incentive Payment System, a program launched in 2017 that determines future Medicare payment adjustments.

Rather than a straight pay-for-service program, MIPS is part of an effort by CMS to transition to value-based reimbursement, fostering a system in which providers are accountable for both quality and costs.

To do this, though, requires that PT and OT participants annually track and report MIPS-based quality measures and improvement activities. This process can be complex and burdensome to clinicians as potential pathway choices are vast.

Since the start of MIPS in 2017, CMS has received feedback from providers that MIPS is confusing and overly complex. For example, there are over 400 quality measures to choose from.  

To help ease this complexity, CMS developed MIPS Value Pathways (MVPs). What MVPs do is provide more straightforward and streamlined options by offering pathways that are more relevant and meaningful to providers.

CMS defines MVPs as subsets of measures and activities tied to a specific specialty, clinical condition or episode of care. By creating MVPs, they’re hoping to move certain specialists away from siloed MIPS reporting and toward more focused sets of measures and activities that are more meaningful to the work they do.

How Are MVPs Established?

New MVPs are both considered and established during the annual CMS rulemaking process.

Each year, CMS accepts new rule submissions for the establishment of new MVPs – called MVP candidates – and from these, they choose various new MIPS Value Pathways they wish to consider.

These value pathways can be provider-specific – MVPs for specific professions or specialties like neurology or rheumatology – or they can be condition-specific. Once chosen, CMS includes new MVPs as part of their proposed rules for the following year.

Thus far, seven MVPs were approved in the 2022 Medicare Physician Fee Schedule (MPFS) final rule, while an additional five have been selected and proposed for 2023.3

Are There MVPs for Physical Therapy? Occupational Therapy?

CMS has yet to select for consideration a rule that would establish specific MIPS Value Pathways for physical and occupational therapy.

This hasn’t been for lack of trying by the team at FOTO®, however.

A Net Health® Company and a CMS-approved Qualified Clinical Data Registry (QCDR), FOTO® has submitted provider-specific MVP candidates for two straight years, including a submission in February of 2022, that would establish an MVP for both physical and occupational therapy.

This submission was made to complement a candidate submission by the American Physical Therapy Association (APTA) that, if accepted, would have established a condition-specific MVP for low back pain.

Unfortunately, it appears CMS may not yet be ready to take on MVPs for PT/OT as neither submission made it into the MFPS proposed rule this summer. This means they will not be considered for news MVPs in MIPS Performance Year 2023.

Will FOTO® Continue Advocating for PT & OT?

As it has for 30 years, FOTO® does plan to continue striving to elevate the rehab therapy profession.

In this case, work will continue in advocating for the establishment of MVPs – both provider- and condition-specific candidates – that create sets of measures and activities that are more focused and meaningful to physical and occupational therapists.

FOTO® is already looking ahead to the 2024 MIPS Performance Year and plans to work with industry stakeholders, such as practicing clinicians and the APTA, to once again develop and submit a candidate MVP proposal to CMS.

At the same time, FOTO continues to strive to make MIPS tracking and reporting seamless and simple for rehab therapists across the country.

FOTO® Patient Outcomes QCDR

Our FOTO® QCDR is a proven solution that helps rehab therapists easily and completely comply with MIPS reporting requirements, allowing them to focus on patient care and other clinic operations.

With FOTO® QCDR, providers may select from 20 quality measures, covering nine quality process measures and 11 quality outcome measures, that are highly applicable to therapy care. They may also report improvement activities that reward ongoing efforts for clinical quality improvement and monitoring.

The data collected through this solution can easily be interpreted and used to guide clinical decisions, helping optimize patient outcomes.

FOTO® QCDR also provides intuitive dashboards and expert support, all of which help ensure therapists are fairly reimbursed for the high-quality care they provide. In fact, 100% of all submitters through FOTO® QDCR achieved or exceeded the neutral payment score for MIPS every year so far.

1 2 U.S. Centers for Medicare & Medicaid Services, Quality Payment Program, “Explore MIPS Value Pathways (MVPs)”

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