Important Changes in the QPP/MIPS/MACRA Final Rule for 2019

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