On January 1st, 2017, the Centers for Medicare and Medicaid Services (CMS) made changes in order to improve its payment for quality programs. It combined several programs into one Merit-based Incentive Payment System (MIPS). We touched on the basics of these changes in our previous article, Value-Based Health Care in the Therapy Clinic. Since that first article, there have been a few updates to recognize before 2019 to ensure that your practice is prepared to meet expectations.
What is MIPS?
MIPS is a scoring system that utilizes four categories of quality care reporting measures to determine if a provider has given “high quality, efficient care supported by technology”. Participants receive a value-based payment adjustment based on:
the weighted MIPS composite score, and
participation in the CMS provider score release that rates providers on a scale of 1-100.
Your MIPS composite score is based on:
Quality, which replaces the PQRS reporting system that providers used through the end of 2016. This category is weighted at 50% of the MIPS score, so you’ll want to get familiar with the list of MIPS quality measures.
Cost, which is only 10% of the equation. This component of the MIPS composite score replaces the value-based payment modifier plan, and determines the payment adjustments based on the scores received in the other categories.
When does MIPS start?
For Physical Therapists, Occupational Therapists, and SLPs, MIPS won’t officially begin until 2019. It is critical you use 2018 to determine the most effective measures for your practice to utilize when the program becomes mandatory.
To determine your current eligibility status, visit https://qpp.cms.gov/participation-lookup. This website contains a variety of important information on this program that you will need in the very near future.
Who participates in MIPS?
All Medicare providers will eventually have to participate in the MIPS program. The current minimum participation thresholds include
“eligible providers with greater than $90,000 in part B allowed charges, or a patient population of greater than 200 part B beneficiaries”.
This threshold is high, and if you don’t meet the criteria and participate, then you cannot reap the benefits. These benefits include an annual +5% adjustment to the Medicare fee schedule through 2019. After that, participants can expect an incremental increase of up to +25% in 2026 and beyond.
In addition to not receiving payment adjustments, there is potential for providers to face damage to their reputation if they are not included in the consumer-based rating.
How do I participate in MIPS?
Prepare now to move forward with MIPS in 2019. If you are an eligible provider, be sure to frequently visit the Quality Payment Program website to learn the necessary requirements for your individual practice. If you’re a provider that falls short of the criteria, there may still be a way for you to participate. There are several EMRs and agencies, such as the APTA, that are moving forward with “virtual” group reporting. Go through the APTA’s webcast to find out more about how this can help you to earn the incentive promised through this payment model.
Even though therapists aren’t currently participating, the collection of quality data is still essential. Eventually Medicare’s program will reach out to include everyone. Stay on top of all the developments to help ease the fee schedule transition.
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