At this point, your head is probably spinning or you’re beginning to stress about how MIPS will impact your practice. The uncertainty surrounding the topic right now (October 1, 2018) and the mix of possible outcomes are causing an already complex subject to be even more complicated. We are going to strip out all the excessive intricate details and simply outline the bare basics in laymen’s terms.
So what should you know at this point?
1.) Physical and Occupational Therapist *may* have to participate in the MIPS program starting in 2019 but a final decision will not be made until November 2018.
2.) There are 4 categories that make up the MIPS program.
a.) Category #1 is essentially the same as PQRS. This can be done through claims-based reporting. StrataPT will prompt for this and take care of reporting all the G-codes for you. The only exception to this is if you have greater than 15 therapists. https://qpp.cms.gov/mips/quality-measures
b.) Category #2 is attesting to Medicare that you participated in certain improvement activities. It involves signing into a Medicare portal and selecting a “Yes/No” to indicate whether you participated in these improvement activities. This will need to be done by March 2020 and StrataPT will provide a clear outline of what these “improvement activities” are and send reminders to assist with the steps that will need to be taken. https://qpp.cms.gov/mips/improvement-activities
c.) Category #3 is reported automatically through your claims submission process and no action is needed on your behalf. https://qpp.cms.gov/mips/cost
d.) Category #4 will not be required of therapists. https://qpp.cms.gov/mips/promoting-interoperability
3.) In summary, only 2 of the 4 categories will require any action from you.
4.) Many therapists will be exempt from the entire MIPS program if certain thresholds have not been met. At this point, the MIPS program will only be required for your practice, if you have met all three of the following:
a.) Have treated over 200 Medicare beneficiaries/year
b.) Have treated over 200 services/year (CMS hasn’t clarified exactly what this means for physical/occupational therapy but it’s safe to say that if you have treated over 200 Medicare patients, then you have treated over 200 services).
c.) Have received over $90k in Medicare payments for the year.
5.) As we get closer to November 1, we will provide a website that can be referenced to determine your participation status and whether you are required or exempt from participating in the MIPS program. Our recommendation will be for everyone to report; however, we will be implementing a practice level setting in StrataEMR to indicate whether your practice will be participating in MIPS which will determine if you will be prompted (automatically) to report the “PQRS-like measures.”
6.) For those that are required to participate in MIPS, the score that you acquire in 2019, would impact your payment in 2021. This impact could vary from -7% reduction in payment to +7% increase in payment based on how thoroughly you report in 2019.
There are an immense amount of complex details buzzing around the MIPS program right now. We don’t want to overwhelm anyone with information that may not even apply to your practice until a final decision is reached in November 2018. However, we believe that it is important to keep you in the loop and at least provide some general information so you can begin preparing mentally and begin to educate yourself on the topic.
Trust that StrataPT will not only continue to stay up to date with all the latest details pertaining to how MIPS will impact your practice but we will also provide the most efficient tools in the industry to assist with the MIPS program if and when it becomes a reality. Relax for now but stay tuned for more information. We’ve got you covered.