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  • Prepare for MIPS: CMS Is Looking for PT Volunteers to Shape the Future of Payment

    It's not often that the Centers for Medicare and Medicaid Services (CMS) allows providers to try out a new system for a couple years before they're required to participate, but that's exactly the opportunity being presented to physical therapists (PTs) under the final 2017 Medicare and CHIP Reauthorization Act (MACRA) released last month.

    In other words, carpe MIPS.

    MIPS, which stands for the Merit-Based Incentive Payment System, is the program most physicians, physician assistants, nurse practitioners, certified registered nurse anesthetists, and groups that include these providers will be required to participate in beginning January 2017. MIPS is a provision of MACRA, the value-based payment system that was put in place after the demise of the flawed sustainable growth rate (SGR), and one that represents a fundamental shift in the way CMS looks at valuation of care. MIPS replaces the physician quality reporting system (PQRS), the value-based modifier program (VBM), and the electronic health records (EHR) "meaningful use" program.

    And according to APTA Director of Regulatory Affairs Roshunda Drummond-Dye, JD, it will almost certainly be the system required of PTs beginning as early as 2019.

    "MACRA is the beginning of the end of CMS reliance on the fee-for-service model," Drummond-Dye said. "These comprehensive efforts will be extended beyond the first wave of providers in 2017, and CMS has definitely not left physical therapy out of its plans for expansion."

    While the move toward value-based care has been long-supported by APTA, there's even better news for members of the physical therapy profession: PTs will be able to voluntarily report to MIPS beginning in January, an opportunity that will not only help them understand the new payment landscape, but will provide CMS with data it can use to structure the program to better position physical therapy when MIPS does become a requirement for PTs. The agency has created a webpage specifically devoted to learning more about participating in MIPS.

    Drummond-Dye says that now is the time to get involved in MIPS, and offers 3 tips that will help make that involvement more successful:

    1. Implement an EHR. "If you don't use an EHR, now's the time to start," said Drummond-Dye. But make sure your EHR is certified by the Office of the National Coordinator—a critical step to ensure that it will be able to work with Medicare and MIPS. "There are only a small number of certified EHRs used by the physical therapy profession, so choose carefully," she adds. The CMS MIPs participation information page includes resources for finding an EHR.
    2. Subscribe to a registry. "Registry participation isn't mandatory, but it's a great way to gain valuable information about your practice and the value of services you provide," Drummond-Dye said. And beginning in early 2017, you can do that by participating in APTA's Physical Therapy Outcomes Registry. It's a resource that does double-duty: not only providing information for individual practices, but stockpiling data that will be used to create robust quality measures that can help the profession position itself well in the future.
    3. Educate your staff, and stay on top of compliance. "It is crucial that each PT understands the importance of quality measurement, and incorporates that understanding into their daily activities," Drummond-Dye said.

    MIPS isn't the only avenue for voluntary participation in the new systems. According to Drummond-Dye, PTs may also be able to participate in the Medicare Quality Payment Program through participation in advanced alternative payment models (APMs). The most applicable models for PTs: the Medicare Shared Savings Program, and the Next Generation Accountable Care Organizations (ACOs). APTA offers background and resources on ACOs on its webpage devoted to the topic.

    "PTs should take a look at area hospitals and physician groups establishing these models, and actively look for ways to take part," Drummond-Dye said. "Participation will not only satisfy MIPS reporting requirements but will also increase the importance of the role PTs play in interdisciplinary teams that are working to improve the quality of care for populations."

    Preparation for the coming changes is also important at the facility level, Drummond-Dye added.

    "Facility-based settings that bill under the Medicare Physician Fee Schedule—rehab agencies, outpatient hospitals, and skilled nursing facilities, for example—need to prepare now," Drummond-Dye said. "CMS hasn't set out a clear path for how these settings will participate in MIPS, but they're working on it," and that’s another move supported by APTA. "To have a strong quality payment program for physical therapy under Medicare, that program must encompass the entire continuum of care," said Drummond-Dye.

    APTA is developing a series of fact sheets on MACRA and will offer a comprehensive plan to help PTs participate in the voluntary reporting program in MIPS. In the meantime, programs such as APTA's Innovation 2.0 initiative are helping to better acquaint the profession with alternative payment models that include significant involvement from PTs.

    Comments

    • This means more work!!! How does this merit based program actually help us?? I'm sick and tired of dealing with all this medicare admin work just to get paid for a service! This is like going to a restaurant and only paying based on your liking or not liking the chef's recipe!! To the people behind this, are you actually practitioners? Do you have your own offices?? This news just pushed me over the edge to look seriously into ending my contract with medicare. You have continued to disappoint me with your pushes in a new payment system. A job is done, we should be paid. It's the only line of work where getting paid is harder than doing our job. I will also be canceling my membership after this year. I'm not paying you to make my work even more miserable. Thanks for NOTHING!!

      Posted by Joanna Bilancieri on 11/2/2016 8:53 PM

    • Joanna, I share your emotions. But I don't think APTA is big enough to change the direction of this ship. I think it is playing with the cards dealt. The days of good hard work and fair reimbursement are gone or at least changing. Some of this is because some of us have shot ourselves in the foot by over billing and overcharging, and bringing scrutiny and more regulation on all of us. We all have to decide which route we can stomach the best. Join in or go cash. APTA has brought us from tech status to respected high paying jobs. AND no matter what rules we have to play under from now on, Physical Therapy is not going away. So it is still a bright but more complicated future. And its not for me either!! I can only pray for those who must keep at it for years to come.

      Posted by John on 11/3/2016 11:18 AM

    • Medicare has been designing complicated reporting systems for providers and gathering data for decades. When are we ever going to know what they have learned from all these burdensome processes. Patient care has become incidental to the process of documentation.

      Posted by Sally Oxley on 11/3/2016 11:57 AM

    • I must also express frustration with the ever increasing amount of administrative work that we must do in order to get paid by medicare. I would like to see the APTA work on reducing the burden rather than seeming to want to pile it on. This is especially a problem for small practices. We do not have the resources to research all of the new nitpicky items that are going to be required in the future. Hiring a "consultant" just adds insult to injury. I hope that I can build a decent cash business before all of this hits the fan.

      Posted by Brian Lambert, PT on 11/3/2016 1:56 PM

    • I know Ms.Joanna remembers why she became a physical therapist & why she is so passionate about her positions at 8:30 pm,following a long day at work. I would focus on what we professionals do best &SERVE where we feel needed & valued----everyday! Kindest regards,Luke.

      Posted by Ralph Lucarelli on 11/4/2016 8:13 AM

    • "While the move toward value-based care has been long-supported by APTA"...this is a problem. Value-based care requires patient compliance and is affected by socio-economic differences in communities. Therapists in poorer communities, should NOT be reimbursed differently. It is this thinking by the APTA that leads to rural healthcare access problems. Fee-for-service is fair and equitable and does not add significant documentation requirements on the therapist so that a non-healthcare office worker can determine "merit" and "value" of therapy. APTA should join with other healthcare organizations to fight this new cumbersome and inequitable reimbursement model or we will only have outpatient and private practice therapy clinics in affluent neighborhoods where outcomes tend to be better because of education levels, job flexibility and resources.

      Posted by Jason on 11/4/2016 9:42 AM

    • In reference to John's comment that PT's have " shot ourselves in the foot ", I contend that this isn't true and never has been true. My evidence would be our salaries. We make much less than PA's, and other providers with less education. The last stats I saw reported that PT's 10 years out averaged 82K, so in what world does this mean we've over billed? Medicare continues to reimburse PT's at a rate well below what they would reimburse others in healthcare BECAUSE THEY CAN! The MD's on the board have always undervalued our professionals and when combined with other fiscal stresses on CMS, we simply fall into a category of providers that are under appreciated and who don't have a large enough PAC, or influential enough national organization to press legislators to support us. We, as PT's, have never been the reason for our poor treatment and we must never believe the shame game applied to us by other PT's or the APTA.

      Posted by Dr. Brian P. D'Orazio on 11/25/2016 4:53 PM

    • Unfortunately, the leadership in the APTA has little representation for the private practice as obvious by John's statement. I have been an APTA member since 1986 and I am more disgusted each year. I was hopeful thinking the APTA dues would gradually pay off. Now it's obvious we have no one representing us.

      Posted by Denise Didio Buher on 12/21/2016 4:52 PM

    • Under the APTA MIPS FAQ, there is a question that asks: Are any outpatient therapy settings able to participate in MIPS in 2017? The anwer is NOT what you have been saying all along......does that mean PTs in PP are suppose to report in 2017?

      Posted by Nisha on 12/28/2016 10:37 AM

    • Hi Nisha. APTA and CMS strongly recommend that PTs in private practice voluntarily report in MIPS in 2017 to gain experience with the new quality program. For more information on MIPS, please see our MIPS Frequently Asked Questions resource at http://www.apta.org/MIPS/FAQ/

      Posted by APTA Staff on 1/3/2017 2:24 PM

    • Looking at Value vs. outcomes can somehow be quite confusing. In the future it appears that if I treat a patient and they do not benefit to the level that some individual or group (who has no direct contact and or knowledge of the patient) deems appropriate, I may be paid at a lesser rate. So.... if I develop cancer and receive the most appropriate care and die, should the facility and or physician in charge of my care be paid ? I would consider death to be a bad outcome!!!, but the staff still deserve to be compensated. Is this any different then a P.T. who treats his patient with compassion, therapeutic procedures and skills and the result may not be as expected? Service and treatment is just that and deserves to be compensated.

      Posted by Dave on 5/11/2017 12:00 PM

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