The decision by the US Centers for Medicare and Medicaid Services (CMS) to include physical therapists (PTs) in its Quality Payment Program (QPP) is huge: not only is it an acknowledgment of the important role PTs can play in the transition to value-based payment; it's an opportunity for the profession to further strengthen its case for physical therapy as a way to reduce costs, improve outcomes, and provide better care.
It's also going to mean some big changes in the ways many PTs get paid for their services, mostly through participation in the Merit-based Incentive Payment System (MIPS), which is a major part of QPP. And the changes are right around the corner, set to take effect on January 1, 2019.
All of which begs the question: are you ready for what's coming? Take this quick quiz to find out how much you know about MIPS (scroll down for answers). Then check out APTA's MIPS webpage for extensive resources on this major shift, and sign up for a December 4 webinar, free to APTA members.
1. True or False: Getting a sense of whether you're MIPS-eligible will be difficult until after January 2019.
2. PTs in private practice who exceed the CMS "low-volume threshold" of more than $90,000 in allowed charges per year, more than 200 unique Medicare patients per year, and more than 200 professional services delivered per year must participate in MIPS or face a payment reduction of how much?
D. There is no penalty for nonparticipation.
3. True or False: PTs who don't meet the low-volume threshold are barred from participating in MIPS.
4. True or False: Group practices can participate in MIPS only if every clinician in the practice meets the low-volume threshold.
5. True or False: Beginning in 2019, claims-based reporting will be permitted only in practices with 15 or fewer MIPS-eligible clinicians.
6. Which of the following statements is the best advice for PTs and practices considering reporting through a vendor or registry to meet MIPS requirements?
A. Hold off for now. MIPS is still in flux and it's hard to predict which arrangements will work.
B. Don't bother. Using an electronic health record (EHR) program alone will get the job done.
C. You missed your chance. At this point, it's too late to integrate with a reporting vendor or registry—your best bet is to go it on your own.
D. It's worth considering. Participating in a registry or other reporting system gives you feedback on performance throughout the year and can ease reporting burdens if the system is connected to your EHR program by capturing data through your daily documentation.
7. In 2019, in addition to quality measures similar to those reported through the old physician quality reporting system, PTs in MIPS also will be required to report on:
A. Improvement activities
B. Promoting interoperability
D. Crossdisciplinary collaboration
8. How many points need to be earned in 2019 to avoid a downward payment adjustment in 2021?
1. False. CMS has a QPP participation lookup webpage available right now. While it's true that CMS will update it to reflect the changes coming in 2019, you can prepare yourself for possible participation by checking to see if you exceeded the participation thresholds in 2018.
2. 7% (C). If you treat Medicare Part B patients and meet all 3 low-volume threshold criteria and don't participate in MIPS in 2019, prepare for a 7% reduction in payment rates beginning in 2021. On the other hand, successful participation in MIPS could result in an upward adjustment of as much as 7%—in fact, it's the only factor on which CMS will be basing increases.
3. False. You can opt in to the program beginning in 2019 if you treat Medicare Part B patients and meet any of the 3 criteria. You can opt in on the QPP website in early 2019 for the 2019 participation year. Check out this decision tree to better understand your options, and remember that once you opt in you’re obligated to participate the whole year.
4. False. For group practices, the threshold criteria (charges, unique Medicare patients, number of professional services) are calculated at the group level—and across services delivered, not just physical therapy.
5. True. Practices with more than 15 clinicians will need to use a vendor to report data.
6. It's worth considering (D). The right vendor or registry can pay off, both in terms of ongoing performance feedback and as a way to streamline data entry by way of integration with your EHR system. Tip: look for a resource, such as APTA's Physical Therapy Outcomes Registry, that has been awarded Qualified Clinical Data Registry status by CMS—that means your MIPS data can be easily passed on to CMS, and may include other quality measures for reporting to MIPS, thereby helping to strengthen your MIPS score.
7. Improvement activities (A). Physicians and other clinicians currently participating in MIPS must report in 4 categories: clinical improvement, quality, cost, and interoperability. For the time being, eligible PTs will be required to report only on improvement activities and quality measures. For more information on both of these categories visit the APTA MIPS webpage.
8. 30 (B). For the 2019 reporting year, participating providers who earn at least 30 points out of a possible 100 can avoid a downward adjustment in 2021.