MIPS participation occurs over a calendar year during which a participating PT or PT practice earns a MIPS score (0-100 points) that will determine whether the PT or practice will earn an upward payment adjustment, have no adjustment, or be subject to a downward adjustment.
In 2019, PTs will need to participate in 2 of the 4 MIPS categories, Quality Measures and Improvement Activities.
Quality Measures
Quality measures are reported for points toward an overall score. (This is different from the old PQRS, which used pass/fail scoring.) The measures available to a PT or practice will be determined by the method of submitting data—claims or vendor. The 2019 PT/OT specialty measure set comprises 11 total measures including 4 claims-based measures (128, 130, 131, and 182). PTs using claims-based reporting should report on all 4 of these measures. PTs who use a vendor will need to report on at least 6 quality measures, including at least 1 outcome measure. PTs should confirm with their vendor which measures are available in their product for reporting in 2019. PTs filing by either claims or vendor may choose to report up to 4 additional measures (126, 127, 154, and 155) outside of the PT/OT measure set if the measures are applicable to their practice and available via their reporting method. For PTs who submit more than 6 measures, CMS will use their top performing measures in calculating their MIPS score.
Below are the measures proposed to be available to PTs in 2019.
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Improvement Activities
This category is new for all providers in MIPS. Improvement activities show that clinicians are engaging in quality improvement
efforts in their clinical practice. Improvement activities must be performed for 90 days or more during the performance year and are
weighted either "medium" or "high" depending on the demands of the activity. To earn full credit in this category, PTs must submit 1
of the following combinations of activities:
- 2 high-weighted activities
- 1 high-weighted activity and 2 medium-weighted activities
- At least 4 medium-weighted activities
From CMS's full list of improvement activities, APTA has identified these activities that physical therapists might implement (see below):
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How to Report: Choosing a Method
PTs can report MIPS data 2 ways: through a third-party vendor, including qualified registries or qualified clinical data registries (QCDRs) such as APTA's Physical Therapy Outcomes Registry; or via claims.
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Claims-Based Reporting
Claims-based reporting will occur as it did under PQRS, with the PT placing a measure code on the claim form. However, only PTs in a small practice—defined as solo providers or those in a practice with 15 or fewer MIPS-eligible professionals—can use claims reporting.
APTA strongly recommends that providers, regardless of size, consider using a vendor for MIPS reporting due to the program complexity and the risk involved with the potential penalties or rewards.
There are drawbacks to claims-based reporting:
- It does not provide feedback on performance until after the close of the reporting year. This means you won't know throughout the year if you need to improve your performance to earn a better score.
- For the quality category in PT/OT specialty set, only 4 measures are available via claims (128, 130, 131, 182), meaning your score will depend on these 4 measures.
- The Improvement Activities category cannot be reported via claims; you will need to enter data manually on the CMS website.
- The administrative burden for claims reporting is higher, since it doesn't allow the same seamless data entry that a registry provides.
PTs who are mandated to participate in MIPS and believe they cannot use a vendor registry may consider claims-based reporting, but they should weigh the vendor cost against the increased risk of facing a negative payment adjustment.
APTA has created data-collection reference sheets for PTs who are reporting via claims in 2019 (an APTA member value). 
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Vendor Assisted
Qualified registries and QCDRs charge for data collection, but they will provide feedback throughout the year to allow PTs to improve their performance if needed to achieve a higher MIPS score. PTs who opt in to MIPS should strongly consider using a vendor to decrease their risk and increase their potential for rewards. All registries provide for reporting in the Quality category, but Improvement Category reporting varies by vendor. Questions you should ask a vendor when considering them for reporting. 
QCDR
Qualified clinical data registries (QCDRs) developed by organizations such as professional associations, are approved by CMS to collect clinical data for submission to MIPS. QCDRs offer the additional benefit of being focused on quality improvement well beyond the MIPS program. QCDRs such as the Physical Therapy Outcomes Registry have the extra flexibility to develop quality measures specialized for their clients, which then are reviewed by CMS for use in the MIPS program. In fact, APTA's Physical Therapy Outcomes Registry anticipates an additional 9 measures for the 2019 reporting year that will focus on demonstrating the value of physical therapist services.
QCDRs should have clinical expertise in quality measurement and be able to provide and demonstrate an understanding of the clinical medicine, evidence-based gaps in care, and opportunities for improvement in the quality of care delivered to patients for PTs.
Qualified Registry
A qualified registry functions primarily to report MIPS measures in the Quality category. Qualified registries must select quality measures from the MIPS measure list that is published by CMS. These registries may or may not support the reporting of improvement activities.
Review details on each of the data collection mechanisms.
Review list of questions you should consider when selecting a vendor. 
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Note: High-priority measures, indicated with a yellow background, are eligible for additional bonus points.
Measure
|
Claims
|
Registry
|
PT/OT Specialty Set
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| Measure 126 - Diabetes Mellitus: Diabetic Foot and Ankle Care, Peripheral Neuropathy: Neurological Evaluation |
|
X |
|
| Measure 127 - Diabetic Mellitus: Diabetic Foot and Ankle Care, Ulcer Prevention Evaluation of Footwear |
|
X |
|
| Measure 128 - Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-up |
X |
X |
X |
| Measure 130 - Documentation and Verification of Current Medications in the Medical Record |
X |
X |
X |
| Measure 131 - Pain Assessment Prior to Initiation of Patient Treatment |
X |
X |
X
|
| Measure 154 - Falls Risk Assessment |
X |
X |
|
| Measure 155- Falls Risk Plan of Care |
X |
X |
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| Measure 182 - Functional Outcome Assessment |
X |
X |
X |
| Measure 217 - Functional Status Change for Patients With Knee Impairment* |
|
X |
X |
| Measure 218 - Functional Status Change for Patients With Hip Impairments* |
|
X |
X |
| Measure 219 - Functional Status Change for Patients With Foot or Ankle Impairment* |
|
X |
X |
| Measure 220 - Functional Status Change for Patients With Lumbar Impairment* |
|
X |
X |
| Measure 221 - Functional Status Change for Patients With Shoulder Impairment* |
|
X |
X |
| Measure 222 - Functional Status Change for Patients With Elbow, Wrist, or Hand Impairment* |
|
X |
X |
| Measure 223 - Functional Status Change for Patients With General Orthopedic Impairments* |
|
X |
X |
*Measures 217-223 use FOTO (Focus on Therapeutic Outcomes) measures.
For a full list of measures see qpp.cms.gov/mips/quality-measures/ (click on "Explore Measures").
Scoring
The score is compiled from the PT's performance in each measure compared with the national benchmark for that measure.
The proposed system for scoring quality measure performance in MIPS is based on 3 classes of measures, as outlined below.
Measure
|
Description
|
Scoring rules
|
| Class 1 |
The measure can be scored based on performance.
The measure meets all of the following criteria:
(1) Has a benchmark;
(2) Has at least 20 cases; and
(3) Meets the 60% data completeness standard. |
Class 1 measures will be awarded 3 to 10 points based on performance compared with the benchmark. |
| Class 2 |
The measure meets the 60% data completeness standard but does not have both a benchmark and at least 20 cases. |
Class 2 measures will be awarded 3 points. |
| Class 3 |
The measure has a benchmark and was submitted but it does not meet the 60% data completeness standard. |
Class 3 measures will be awarded 1 point, except for small practices, which will receive 3 points. |
Review APTA Physical Therapist MIPS Improvement Activities (.pdf)
To be eligible to receive maximum points, PTs must make sure to submit data on 60% of all eligible patients on at least 20 cases for measures with a CMS-established benchmark. PTs also can earn bonus points by reporting more than 1 high-priority Class 1 measure.
For a full list of activities see qpp.cms.gov/mips/improvement-activities (click on "Explore Activities").