Got MIPS Questions? We Have Answers.
The Merit-based Incentive Payment System (MIPS) is now in effect for many physical therapists. At a recent live webinar, APTA answered some of our members' most pressing questions. (In case you missed it, you can listen to the recorded webinar in its entirety.)
We've recapped some popular questions here. Not finding the question you need answered? You can email firstname.lastname@example.org. APTA members can also post questions, and review answers to other member questions on the Medicare MIPS Discussion Board on the Medicare Quality Reporting Hub.
What is the quickest way to find out if my practice is required to participate?
The Centers for Medicare and Medicaid Services (CMS) website has an easy lookup tool. Just type in your national provider identifier (NPI) number and you'll see whether you are required to participate as a practice, or as an individual.
APTA's MIPS resource page has a lot of information, including a decision tree to help you understand MIPS eligibility and required vs voluntary participation.
In brief, you must participate if you are an individual PT in private practice and exceed all 3 criteria for the "low-volume threshold":
- Receive more than $90,000 in Medicare part B payments each year
- Provide care for more than 200 Part B-enrolled Medicare beneficiaries annually
- Bill more than 200 professional services annually
My small practice is going to participate in MIPS. Because we have fewer than 15 PTs, we are allowed to report via claims instead of through a registry or QCDR. What are the business considerations for choosing one method or the other? Can we switch from claims to registry reporting later, or are we stuck with whatever choice we make?
If you report via claims, you can submit your quality data on your claim form. However, you will not get feedback on your performance until after the end of the reporting year, when it will be too late to make changes that could help your MIPS score. Even though you will incur a cost using a registry, it will provide you with feedback throughout the year. The type and frequency of feedback may vary by registry. You can switch data submission methods mid-year. CMS will base your score on your top 6 measures.
Does MIPS apply to hospital-based outpatient practices?
No. For 2019, if you practice in a facility-based setting such as a hospital outpatient department, skilled nursing facility (part B), or rehabilitation facility you are not able to participate in MIPS.
Our physical therapy clinic is part of a multispecialty practice in which the physicians already report as a group. The PTs do not meet the low-volume threshold as individuals. Do we need to report as part of the group?
It may depend on your specific multispecialty practice. You can contact us at email@example.com to address your questions.
We have 6 PTs in our practice, and none of them exceed the low-volume threshold individually. But as a group, we do. Do we have to report?
The group is not required to participate, since MIPS only mandates individual PT participation. However, because the practice as a whole exceeds the threshold, it can choose to participate in MIPS to take advantage of the potential 7% incentive payment.
Our practice exceeds the threshold, but only 1 of our PTs does individually. How does that work?
You have 2 options: The PT participates alone, or the practice can participate as a group. Only the PT who exceeds the threshold is required to participate. However, because the whole practice also exceeds the threshold, it can participate in MIPS. If you choose group participation, all therapists will be considered fully participating in the program.
What are my options for reporting improvement activities? Do you have recommendations?
CMS offers over 100 improvement activities, which can be found on the CMS QPP website. APTA has created a condensed list of activities that may appeal to PTs.
How can we follow our performance scores to tell if we are meeting expectations throughout the year?
This is a great question. If you report via claims, you will not know your score until the end of the reporting year. This is why APTA recommends using a vendor for reporting. It can help you improve your scores throughout the year. If you report using a "qualified registry," check with your vendor to see how frequently you will be able to get feedback. Some may only be quarterly or monthly.
As a qualified clinical data registry (QCDR), APTA's Physical Therapy Outcomes Registry gives you continual real-time feedback.
If you are attending CSM, Heather Smith, PT, MPH, APTA director of quality, and Kara Gainer, JD, director of regulatory affairs, will be presenting "Emerging Issues in Medicare: Quality Programs and Alternative Payment Models" on Friday at 11:00 am, where a CMS representative will be available to address attendees' questions. Heather Smith also will host a Q&A session at 2:00 pm on both Thursday and Friday at the Physical Therapy Outcomes Registry booth #1433 in the Exhibit Hall.