I am an unabashed believer in outcome-based reimbursement for medical services and I believe that all payers will soon be adopting something similar to what Medicare is currently doing. While I don’t believe that methodology being used is necessarily the best way, I believe it will get better over time. It is the playing field we are on today. We work with our clients to “avoid all penalties, maximize the bonuses while doing the least amount of additional work possible.” To that end we are always looking at the best way to approach the QPP and other programs to give you the best advantage. This is more important today since CMS has frozen reimbursement rates for therapy for the coming years. This is the only way to increase revenue and stay in business.
Important 2019 QPP Final Rule Changes (especially for our Therapy clients)
1. Physical therapists, occupational therapists, qualified speech-language pathologists (speech therapists), qualified audiologists, clinical psychologists, and registered dietitians or nutrition professionals are now eligible to participate in MIPS.
2. The low volume threshold to qualify for participation with MIPS will remain the same for 2019 with couple of slight twists. Clinicians must have more than $90,000 in Medicare Part B fees and more than 200 individual patients but also could qualify if they have more than 200 covered Part B services. Also, those that are below the threshold may be able to “opt in” to the program if they wish.
3. The minimum score necessary to avoid a 7% penalty for all of 2021 is raised to 30 points. That threshold had been at 15.
4. The Exceptional Performance Threshold has been raised from 70 to 75 for 2019. That is the level where additional bonuses become eligible.
5. Categories for MIPS will remain the same for 2019 but the weighting will change slightly: Quality Measures – 45%, Promoting Interoperability (PI) – 25% , Improvement Activities – 15%; Cost – 15%.
6. For Therapy this is a big one. For the 2019 reporting year, Therapy (PT/OT/ST) have the option to not report on the PI (Promoting Interoperability) category. If they choose not to report in this category the Quality Measure category will be reweighted accordingly (basically to 70% of the MIPS score). Many therapists are cheering about this one, I recommend you think this through.
Before you decide to exclude yourself from reporting the PI (Promoting Interoperability) measures!
This optional exclusion is only available for a short time (likely just this year). CMS made this exclusion under pressure because of input that many therapists do not have Certified software in their practice and this will give them a year (or more) to acquire the hardware and software that is required.
For those of you that already have certified software, it may be to your advantage to report PI measures to enhance your overall score. Here are some reasons why. Both PI and Improvement Activities need only be reported for 90 days to get full credit. Most of these activities are not only decided upon but are actually implemented at the corporate or ownership level and may only need limited input by your therapists. That could be 40 of your possible 100 points. In fact, if your goal is to only avoid the penalty, you are done! I don’t recommend that by the way. You are leaving too much money on the table for the minimal effort needed to get the rest.
Quality measures (45% of your score) are always dependent on your therapists accurately entering data (minimal as it is) on every patient (at least on evals and re-evals). This activity must happen for 365 days and is totally dependent on your therapists being diligent.
I recommend that you complete both the PI requirements and the Quality Measures. It is very little extra work. Then at the end of the reporting period you can evaluate what data to report to give you the best score.
Your MIPS score is not only valuable for marketing purposes but the financial penalty and reward is great. Next year the penalties and bonuses go even higher. Your decision to participate or not will effect your bottom line revenue by as much as 14%. Think about that. If your office just does $500,000 in Med B that would equate to a as much as a $70,000 difference in your bottom line. Definitely worth paying attention to….
…….until next time. Mike

As a kid we used to play pickup games of baseball in our street. We would use trash can lids and sewer covers for bases, a bat if someone had one, a broom if we needed to, and of course a tennis ball so we didn’t break any windows. Everyone was invited and whoever showed up got to play. It’s a lot more fun to talk about than performance based reimbursement but it reminds me of the current state of MIPS.

91% of eligible providers participated in MIPS in 2017, and that number is extremely important. At least nine out of ten providers did enough to earn the minimum three points. If we had that kind of turn out in the neighborhood there would have been talks of matching uniforms! So why is that number so important?

It tells us that just having a MIPS score is not going to be enough. We talked with many providers that were going to meet the minimum requirements. They were going to talk to one patient, submit one quality measure and avoid a penalty. Those providers can congratulate themselves on being part of the 91% but are missing out on a greater opportunity. They may have avoided a penalty but also a bonus.

The MIPS playing field has changed, it’s getting more competitive. Eligible clinicians are up to bat at home plate in Wrigley field and a broomstick just isn’t going to cut it. If you’re not meeting the exceptional participation level which was set at 70 in 2017 you’re not doing enough. 91% participation is great, but it is definitely not the whole story. When MIPS scores are published in a few months it will be easy to see who is leading the way.

Quality care is not a game, its serious business and the clinicians that are achieving the high MIPS scores will be rewarded. Like any good baseball player, it takes dedication and guidance. There are a lot of resources out there that will inform you of requirements and how to meet the minimum. A MIPS coach will help you maximize your performance and go beyond participation. Clinicians we have worked with have performed above the exceptional level and will be rewarded for their effort. Go beyond participation, effect real change, improve your MIPS score, and earn a larger reimbursement. Call Access1 today to schedule a free MIPS consultation with one of our certified coaches.

CMS has responded to numerous requests to update and expand the MIPS eligibility look up tool. In the past, providers were able to look up their individual MIPS eligibility via the QPP page. Though this tool would only allow you to view individual eligibility. The most recent update now allows you to view MIPS eligibility at the TIN level. If you have multiple clinicians that bill Medicare under the same tax identification number you can now check eligibility for all providers in one easy step.

The increase in MIPS eligibility requirements from $30,000.00 in Medicare payments and at least 200 Medicare beneficiaries has left a lot of providers who were eligible for bonuses in 2017 on the outside looking in. We have spent a lot of time this year focusing on how providers who do not meet the increased eligibility requirements can still take advantage of the MIPS bonus opportunities. The easiest way is to participate as a group. If you a physician does not qualify as an individual they may still qualify at the TIN level.

If you used the QPP submission portal for 2017 reporting the hard work is already done. You can use your EIDM portal log-in on the CMS page to access the MIPS eligibility tool and check your status of your group. While your on that page you can also view your estimated MIPS score for the 2017 reporting period. If you haven’t set up your EIDM log-in or want some direction please contact an Access1 MIPS coach. We will walk you through the process and get you on the road to earning a MIPS score in 2018. Call 970-460-9392 or email us at info@access1234.com today to schedule a free MIPS assessment.

What a difference a year makes! An adage that could be applied to anything and in the case of MACRA, the QPP, and MIPS it means everything. Twelve months ago, Medicare providers were just learning about their eligibility and had months to figure out what they wanted to do about it MIPS.

Fast forward to 2018 and those providers that submitted MIPS data are waiting to learn how much of a bonus they will earn in 2019. Those that didn’t are trying to justify the looming penalties and the fact that they are again playing catch-up. Provider frustration with added burden and a plea for a reprieve resulted in an increased the eligibility threshold. Some hoped that MIPS would go away but the new eligibility requirements have only excluded a large number of providers from earning a bonus in 2018.

What we’ve learned is that MIPS can’t be ignored, it’s not going away. Not only is it still here, it’s bigger, its more complex, the benefits are greater, and it requires a great effort for success. All providers, regardless of eligibility should embrace the MIPS program as an opportunity and should apply maximum effort to earning a full MIPS score.

In a few months CMS will publicize a comprehensive list of MIPS scores including all the providers that did not earn a score. Patients will have access to this list and will use it when choosing a provider. You can also expect to see private insures take notice of these scores, and we believe that they will soon adopt a similar pay for performance plan.

We believe that the raised eligibility requirements are not an ease of burden but are an exclusion. No one likes to be excluded from anything, especially when it comes to making more money! The take away is that participating in MIPS is of greater importance than avoiding a 5% penalty, it goes beyond the possible 15% bonus. Published MIPS scores will soon have an effect on how many new patients you see and will also have an impact on your non-Medicare payments. Physicians, especially small practices cannot afford to pass on MIPS this year.

The quality reporting period started January 1st of this year. You can’t wait any longer to get started. Call Access1 today to speak with a MIPS coach. We will confirm your status and establish a plan to help you stay competitive in a new MIPS market.