If you’re a practitioner who provides rehab therapy services in the U.S., and a portion of your clients pay for these services through Medicare Part B, it’s likely you’ve heard a thing or two about the Medicare payment program called MIPS.
MIPS has been around since the start of 2017. Yet, we continue to encounter confusion among physical therapists (PTs), occupational therapists (OTs) and speech-language pathologists (SLPs) about what the program is, what it does, and how it directly affects them.
This is certainly understandable. MIPS is a government program, after all, and in case there was any confusion about this, it bears many of the more familiar marks of such a program:
- It’s big.
- It’s confusing.
- A lot of smart people in rehab therapy are still unsure how best to comply with, and benefit from, MIPS.
Thankfully, we at FOTO® Patient Outcomes, a Net Health® company, are experts when it comes to MIPS. In fact, FOTO® provides a CMS-approved Qualified Clinical Data Registry (QCDR) that helps PTs, OTs and SLPs meet their annual MIPS reporting requirements.
So, we’re here to help.
To begin, let’s start with the basics. Below is a simplified overview of MIPS – what it is, why it exists, and how it may affect you as an outpatient or private practice rehab therapist.
What is MIPS?
MIPS stands for Merit-Based Incentive Payment System, which is a program that determines future Medicare payment adjustments.
Unlike the Sustainable Growth Rate (SGR) law that previously outlined a straight fee-for-service payment program, MIPS pays out based on the composite performance scores of eligible clinicians (ECs). From these scores, ECs – which can include physical, occupational and speech therapists – may receive positive payment adjustments, bonuses, or negative payment adjustments.
In other words, rehab clinicians (or groups of clinicians) who participate in MIPS receive Medicare payment adjustments based on the quality of services they provide as well as the steps they take to improve their clinical practice, also known as “improvement activities.”
The rub is that this requires participants to track and report MIPS-based quality measures and improvement activities every year, a process that may scare providers away from opting into the program … that is, if they are not otherwise exempt.
Why Does MIPS Exist?
MIPS was born from an ongoing effort to provide affordable, high-quality healthcare to Medicare recipients. The program was established with the passing of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).
In place of the SGR model, MACRA tied payments to quality, cost-efficient care. The goal of this was to drive improvement in care and outcomes, increase the use of healthcare data and information, and to ultimately reduce the cost of care.
Am I Required to Participate in MIPS?
Physical, occupational and qualified speech-language pathologists can participate in MIPS as individuals, or as part of groups or virtual groups.
While groups cannot be required to participate in MIPS (we’ll focus on groups in another post), you as an individual rehab therapist may be required if you match or exceed all of the following low-volume thresholds (LVTs) during preliminary and final eligibility determination periods:
- You bill more than $90,000 for Part B-covered professional services
- You see more than 200 Part B patients
- You provide more than 200 covered professional services to Part B patients
If you as a practitioner do not meet all the above thresholds (a.k.a., you are exempt from MIPS), you can still elect to opt in to MIPS as an individual. You’re eligible to do so this year if you meet all of the following requirements:
- You are identified as a MIPS eligible clinician type on Medicare Part B claims
- You have enrolled as a Medicare provider before 2021
- You are not a Qualifying APM Participant (QP)
- You exceed one or two of the three LVT criteria listed above
Why Would I Opt-In to MIPS If Not Required?
This is a question you’re likely asking yourself if MIPS isn’t currently a requirement for you as a provider. If you don’t serve Medicare patients, then of course you do not need to worry about MIPS. But, why go through the effort of tracking and submitting quality measures if you don’t have to?
The main answer is the 2015 MACRA legislation made the fee for service budget neutral. Therefore, MIPS becomes the only way for you to increase your reimbursements for services you provide to Medicare Part B patients.
But beyond increasing revenue, participation in MIPS can benefit you and/or your clinic by helping you better focus on quality of care and outcomes, as well as helping you prepare for future value-based program requirements, which seem to be the trend in healthcare.
What If I Don’t Participate in MIPS?
Again, if you see no Medicare patients, MIPS is not something you need to be concerned about.
However, if you are required to participate in MIPS in 2022 and you opt to not participate in the program, you will lose money. A penalty will be applied to Medicare Part B fee-for-service (FFS) claims in 2024, all of which will receive a -9% payment adjustment.
Do Any Tools Exist that Can Help Me With MIPS?
Of course. FOTO® Patient Outcomes QCDR is a proven solution that helps rehab therapists across the country easily and completely comply with MIPS reporting requirements while helping improve overall care within their clinics.
Using FOTO® QCDR, rehab therapy 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 be easily interpreted and used to guide clinical decisions, helping optimize patient outcomes.
FOTO®’s QCDR tool 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.
To learn more about FOTO® Patient Outcomes QDCR, and to schedule a demo, contact us today!
