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
The MIPS playing field
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.
MIPS Eligibility Look-up Tool for Group Reporting
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.
A New Strategy for a New Year of MIPS
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.
Who’s in and who’s out?
CMS has released the updated 2018 MIPS Eligibility Tool. Clinicians are now able to look up their MIPS status for year two using their NPI. Eligibility requirements were increased from $30K in Medicare payments and 100 beneficiaries in 2017 to $90K in Medicare payments and 200 beneficiaries in 2018. This has left many providers who participated in 2017 on the outside looking in. Please use the link below to access the eligibility tool to find out if you’re eligible to take advantage of the 5% MIPS bonus in 2018.
Want to know more information, or find out what your status means? An Access1 MIPS coach answer your questions, check your status, and offer solutions to help you take full advantage of the quality payment program. Even if you participated in MIPS in 2017 there have been significant changes to the breadth of the program. This includes new participation categories and scoring thresholds. Successful participation starts with a full understanding of MIPS, exactly what a dedicated MIPS coach can offer. We are available by phone and email, or you can use the link below to schedule a complementary MIPS evaluation.
Navigating the 2018 MIPS program
The 2018 MIPS final rule has been published. After months of accepting feedback from various stakeholders CMS has unveiled the second iteration of the Quality Payment Program. There was a lot of feedback from small providers that the MIPS program was too much of a burden. Participation requirements were too complex and added too much work to an already overworked group of providers. These providers obviously did not have a MIPS coach helping them navigate the program! For additional information and ways to get help, download our MIPS Quickstart Guide and learn about the MIPS Method.
Changes were made to ease the burden for small providers by raising the eligibility requirements. Groups and providers that have less than or equal to $90,000 in Medicare Part B charges and 200 beneficiaries are exempt from participation.
While the burden of participation has been eased, complexity of the requirements has not. Clinicians must still navigate the process of selecting appropriate quality measures. Quality measure considerations should include topped out measure scoring, and submission method thresholds. In addition providers will need to select appropriate Improvement Activities, taking into account those activities that may provide bonus points for the ACI category.
The 2017 transition year provided an opportunity for clinicians to avoid penalties while submitting a minimum amount of data. In a move to align the scoring threshold with the spirit of the Quality Payment Program the performance threshold has been raised to 15%. In addition to raising the performance threshold, data completeness minimums have been raised to 60% for the coming year. The goal was to ramp up the level of performance as we move to a fully implemented MIPS program in year 3.
Though the requirements and scoring thresholds have increased there are also new incentives for small practices and quality measure options that give providers bonus opportunities. The 2018 Quality payment program will offer eligible providers a good opportunites to earn a positive payment adjustments. The most important thing that you can do is to work in a MIPS Coach who will expertly guide you through the reporting options. To learn more about the Quality Payment Program and out MIPS coaching please check out our MIPS Method.
2018 MIPS Year Two Final Rule
There has been much debate about what changes would be made to the MIPS program for the second reporting period after the 2018 Proposed Rule came out earlier this year. The Final Rule for the 2018 Quality Payment Program was announced on Thursday, November 2nd. Many of the proposed rule changes were upheld by CMS. The quality payment program will ease the burden for small practices and continue to transition toward a more robust program when MIPS will expand in year 3. Here are some key takeaways from the final ruling.
– The addition of the Cost Performance Category will be added in 2018.
– The Quality Performance Category weighting has been reduced.
– The minimum performance threshold has been raised in year 2.
– Practices using 2014 Edition certified software will be able use their CEHRT for the 2018 reporting period. Clinicians can use either 2014, 2015 or a combination of the two certified editions, however a bonus can be earned by using only a 2015 CEHRT.
– Clinicians treating complex patients will automatically be awarded up to 5 bonus points.
– Small practice clinicians will receive a 5-point bonus.
– Virtual groups have been added as a reporting option.
– Adjustments to MIPS eligibility requirements will exclude those providers with≤$90,000 in Part B allowed charges or ≤200 Medicare Part B beneficiaries.
Some of the transitional features of the 2017 reporting year will carry over for the next reporting period. In 2017 providers could choose to submit a minimum amount data to avoid penalty. The performance threshold remains low but has been increased from 3% to 15%. Like the transition year, meeting this threshold allows providers to avoid MIPS penalties. New to the program for the 2018 year will be the Cost performance category. This new scoring section will represent of 10% of the final MIPS year two score, giving providers another opportunity to increase their chances of reimbursement bonus. As a result of the new performance category, the weighting of the Quality Performance category will be reduced to 50%.
Two of the most important changes for 2018 include the reduction in number of eligible clinicians and the addition of Virtual group reporting. CMS received a lot of feedback from small practices and individual providers that addressed the added burden of participation in MIPS. To ease this burden the decision was made to increase the eligibility requirements to exclude those providers with less than $90,000 in Medicare Part B charges and fewer than 200 beneficiaries. In addition to raising the participation requirements CMS has allowed participation through Virtual groups. Eligible individual providers may participate within a group with different TINs.
You can read more about the Final Rule which is available through the CMS webpage. If you’d like to know how you can take advantage of the MIPS program to increase your Medicare reimbursement call Access1 today. A MIPS coach will help you plan for the 2018 reporting period and review your 2017 status.
Don’t wait, don’t do the minimum, here’s why!
We’ve entered the final quarter of 2017 and with it the final chance to record 90 days of MIPS data. Clinicians looking to fully participate in the MIPS 2017 reporting period must submit at least 90 days worth of data to receive full credit. So what does this mean if you haven’t started? There are still options for providers who are required to participate to avoid the 4% penalties.
The 2017 reporting year, and the Pick Your Pace plan allows clinicians to meet a 3% performance threshold to avoid penalties. It is true that you can submit data for 1 measure for 1 patient to receive a neutral payment adjustment in 2019. However, we advise that this participation level will only cause more work in the future.
The year 2 proposed rule for MIPS includes a propsed adjustment to the performance threshold from 3% to 15%. This means that next year clinicians will need to submit more than one quality measure, and data for more than one patient visit to meet the minimum threshold. Gone too is the abiltiy to report for a 90 day period. Clinicians must submit data for the entire 12 month reporting period and not a minimum of 90 days.
What does Access1 suggest? Report as much data as you possibly can in the first year. By selecting 6 quality measrures you are sure to avoid a negative payment adjustment. You will also set yourself up to collect the maximum amount of MIPS data starting January 1, 2018. Don’t wait and play catch-up, get ahead of the game today. An Access1 MIPS coach will guide you through the all areas of the MIPS program.
Next year penalties and bonuses increase to 5%. Many clinicians can not afford to give up 10% of their Medicare reimbursment. Call Access1 today to speak with a MIPS coach, create a plan for 2018, and see how easy it is to secure a bonus.