Should You Opt into MIPS? Consider These Recent Rehab Therapy Statistics

By Rick Gawenda, PT Founder & President, Gawenda Seminars and Consulting

Since 2019, physical therapists (PTs), occupational therapists (OTs), and speech-language pathologists (SLPs) have been eligible clinicians for the Merit-based Incentive Payment System (MIPS).

For the 2022 MIPS Performance year, approximately 3.5% of PTs, 1.7% of OTs, and 0.34% of SLPs were required to participate. Though the vast majority of these rehab therapists are not required to participate in MIPS, many of them have the option to opt-in each calendar year and participate in the MIPS program.

But should they?

In this article, I will share data from the Centers for Medicare and Medicaid Services (CMS) for the 2022 MIPS Performance Year that impacts therapists’ 2024 Medicare payments.

What Have We Learned from MIPS?

What were the mean and median final scores for the 2022 MIPS Performance Year?

The mean final score for all MIPS eligible clinicians was 82.90 points, and the median final score was 85.29 points.

What were the mean and median payment adjustment amounts for the 2022 MIPS Performance Year?

The mean payment adjustment amount was 2.06%, the median was 0.92%.

What was the maximum positive payment adjustment amount for the 2022 MIPS Performance Year?

The maximum payment adjustment amount for this Performance Period was 8.26%.

For the 2022 MIPS Performance Year, how many MIPS-eligible clinicians were there? How many did of them did not report?

Within this Performance Year, there were 624,209 MIPS-eligible clinicians. Of those, 37,038, or 5.93%, did not report.

For 2022, how many physical therapists were required to report MIPS?

In 2022, there were 19,942 physical therapists (PTs) required to report MIPS. Of those, 523 PTs chose not to submit data. This means that 2.62% of PTs who were required to submit MIPS data did not submit MIPS data for one reason or another.

For 2022, how many occupational therapists were required to report to MIPS?

In 2022, there were 2,405 occupational therapists (OTs) required to report MIPS. 39 OTs chose not to submit data. This means that 1.62% of OTs who were required to submit MIPS data did not submit MIPS data for one reason or another.

For 2022, how many speech-language pathologists (SLPs) were required to report to MIPS?

In 2022, 583 SLPs were required to report to MIPS. All of them complied during this Performance Year.

In 2022, how did MIPS eligible clinicians choose to participate in the MIPS program?

For the 2022 MIPS Performance Year, MIPS eligible clinicians participated in the following four ways:

• 46,242 (7.41%) participated as an individual
• 427,425 (68.47%) participated as a group
• 94 (0.02%) participated as a virtual group
• 150,448 (24.10%) participated as an Alternative Payment Model (APM) entity

What are the overall payment adjustments the 2022 MIPS eligible clinicians will receive in calendar year 2024?

The 2024 MIPS Payment Adjustments are as follows.

• -9% payment adjustment for scores between 0 – 18.75 points: 2.09% of MIPS eligible clinicians will receive the maximum negative payment adjustment.
• -6.75% – 0% payment adjustment for scores between 18.76 – 74.99 points: 11.48% of MIPS eligible clinicians were in this range.
• 0% payment adjustment for a score of 75 points: 7.17% of MIPS eligible clinicians received 75 points.
• 0% – 1.25% payment adjustment for a scores between 75.01-88.99: 37.04% of MIPS eligible clinicians were in this range.
• 1.55% – 8.26% payment adjustment for a score between 89-100 points: 42.22% of MIPS eligible clinicians were in this range.

What are the payment adjustment percentages for physical therapists in 2024?

• Maximum -9% Payment Adjustment: 380 PTs (1.91%)
• -6.75 – 0% Payment Adjustment: 2,088 PTs (10.47%)
• Neutral Payment Adjustment: 381 PTs (1.91%)
• 0% – 1.25 Payment Adjustment: 6,222 PTs (31.20%)
• 1.55% – 8.26% Payment Adjustment: 10,871 PTs (54.51%)

What are the payment adjustment percentages for occupational therapists in 2024?

• Maximum -9% Payment Adjustment: 36 OTs (1.50%)
• -6.75 – 0% Payment Adjustment: 330 OTs (13.72%)
• Neutral Payment Adjustment: 35 OTs (1.46%)
• 0% – 1.25 Payment Adjustment: 994 OTs (41.33%)
• 1.55% – 8.26% Payment Adjustment: 1,010 OTs (42.00%)

What are the payment adjustment percentages for speech-language pathologists in 2024?

• Maximum -9% Payment Adjustment: 0 SLPs (0.00%)
• -6.75 – 0% Payment Adjustment: 52 SLPs (8.92%)
• Neutral Payment Adjustment: 3 SLPs (0.51%)
• 0% – 1.25 Payment Adjustment: 283 SLPs (48.54%)
• 1.55% – 8.26% Payment Adjustment: 245 SLPs (42.02%)

What type of MIPS eligible clinician has the highest rate of not reporting?

Solo practitioners have the highest rate of non-reporting clinicians and this rate is approximately 51%.

Where can I access additional information regarding the 2022 MIPS Performance Period results?

Visit the Quality Payment Program portion of the CMS website. I would recommend you download and read the following two reports:

• 2022 QPP Participation and Performance Results At-A-Glance
• 2022 QPP Experience Report

Is MIPS Worth It for Me?

To determine this, first consider that if you scored 100 points in the 2022 MIPS Performance Period, you would receive an 8.26% positive payment adjustment to your 2024 Medicare payments. To put this into perspective, for every $100,000 the Medicare program reimbursed you in calendar year 2024, you would have received an extra $8,260.

To determine the true ROI of this effort, you would need to determine and subtract your costs for participating in MIPS in 2022 (i.e. time, money, resources, etc.) to reveal the program’s true value. Then, you can determine if the payment adjustment you are receiving is worth it.