In 2017 PQRS became a "legacy" program and was rolled into the Merit-based Incentive Payment System (MIPS)—which, in turn, is part of the new Quality Payment Program (QPP) created by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Under the new QPP, providers can opt to participate in 1 of 2 tracks: MIPS or Advanced Alternative Payment Models (Advanced APMs). Physical therapists are not formally included in MIPS in 2018 but can report voluntarily, and they may be added to the program beginning in the 2019 reporting year, which will affect payment in 2021.
APTA and CMS strongly recommend that PTs voluntarily report in MIPS in 2018 to gain experience with the new quality program. To voluntarily participate, PTs can continue reporting the former PQRS measures, now an element of MIPS, via claims-based reporting.
For more information on MIPS see our FAQ (.pdf) and stay tuned for new member resources on MIPS.
MIPS for 2019
The Centers for Medicare and Medicaid Services (CMS) has proposed, as part of the 2019 physician fee schedule, to require many PTs in private practice to participate in the QPP program through either MIPS or advanced APMs beginning January 2019. Additionally, CMS has proposed to allow certain other PTs and physical therapy practices to opt into the program, enabling them to earn incentive payments and to prepare for participation in APMs.
MIPS for 2018
MIPS, like the previous PQRS program, requires providers to submit quality data throughout the year for an annual scoring. Unlike the PQRS program, MIPS requires reporting in 4 performance categories, several of which need to be reported electronically through registries or certified EHR vendors. Providers earn points in each category, producing a total annual MIPS score. That score will determine whether the providers earn a payment incentive, remain neutral in payment, or be subject to a penalty. As with PQRS, payment incentives and penalties under MIPS will kick in 2 years after the data-collection year. So, for example, if reporting were mandatory for PTs this year, MIPS data for 2018 would determine incentives and penalties in the 2020 payment year. Payment incentives and penalties are much higher under MIPS than they were under PQRS: plus and minus 4% in 2019, 5% in 2020, 7% in 2021, and 9% in 2022 and beyond.