Facts about MIPS

**This Information is not owed by HENO. Please ensure to get the most current and up to date information you visit: CMS MIPS Overview

Information about G-codes in 2019: CMS Functional Reporting

Reporting is Based on 4 categories:

1. Quality Reporting Requirements
2. Promoting Interoperability Reporting Requirements
3. Cost
4. Improvement Activities

Reporting Can be done as:

• Individual with their NPI/TIN
• Group TIN
  • If you don't qualify as an individual you may be able to report at the full group
  • Large Practice: 16+ eligible providers
  • Small Practice: Fewer than 15 eligible providers
• Virtual group with 10 or less NPI with a TIN

Who may be eligible?  PT, OT, and SLP in a private practice setting

What is a private practice setting?  Any practice submitting claims with a 1500 form/837P Electronic Claims. This means practices using HENO are considered private practice settings!

Two Phase Determination Periods:

• Phase 1: 10/1/17-9/30/18 (30 days claims run-out)
• Phase 2: 10/1/18-9/30/19 (will not include the run-out)

Are you required to participate?

•    All if you EXCEED all three of the thresholds during BOTH determination periods

1.       You have > 90,000 in part be allowed charges

         Medicare allowed amount prior to the multiple procedure payment reduction policy

2.       You evaluated and/or treated > 200 unique Medicare beneficiaries (patients)

         It is counted by the claim submitted.

         Example: if a patient is seen by one provider it is one unique visit and then if seen by another it will count towards their unique visits as well.

         You will need to exceed 200 unique patient visits inside of the determination periods

3.       You provided >200 covered professional services under the Medical Physician Fee Schedule

         It is counted by the single line

         Example: If you see a patient and bill 97530 with 3 units on ONE line, this is a single professional service. But if you charge it on 3 separate lines, this will be 3 professional services.

• If you did not exceed the 3 thresholds in the first segment analysis, but you did in the second determination period. You will be excluded without being required

Can you Opt-In to participate? Yes

•    If they meet or exceed at least one or two, but not all, of the thresholds, a practice can chose to opt-in MIPS, but will not be required.
•    How can you participate?
  
  •   Make an election via Quality Payment Plan Portal
    
    • Create account
    •  Log into the account
    •  Select one:
      
      • Opt-in (positive, neutral, negative)
        • THIS IS IRREVOCABLE
      • Remain excluded and voluntary report data
        
        • Not eligible for payment adjustment (or at risk for adjustments)
        • Virtual groups cannot report data voluntarily (will have to opt-in if they chose to opt-in)

Should you opt-in?

• Look at all the therapist in facility and do any of them exceed the thresholds?
• If you are part of a group the individuals can opt-in separately.
  
  • They will do the NPI/TIN and give the best score

When will you see the adjustment in payments?

The 2019 year will reflect in the 2021 year. This could result anywhere from a -7% to +7%.

For future years starting 2020 (based on a 2 year after Performance Year) could result in a -9% to +9%.

Incentive Payment System

•  Up to 6 quality measures and one outcome measure for the 12-month calendar year with 60% completeness
  
  • Claims reporting: 60% in on all Medicare Part B only (Traditional only not Medicare advantage)
  • Registry reporting: 60% calculated on all patients (Medicare and non-Medicare patient)
• If outcome measures are not available you will want to report a High priority measure in place of it.
•  If fewer than 6 measures apply CMS will adjust your denominator for the Quality category by 10 points for each measure that isn't available

1.       Quality Measures (45% of Final Score)

• Against a benchmark will receive 3-10 points
• Topped out measures are capped at 7 points (meaningful distinctions and improvements in performance can no longer be made)
• With no benchmark or do not meet case min (20 cases) will be 3 points
•  Did not meet data completeness requirements (60%) will only get 1 point.
  
  • If you are a small practice you will receive 3 points

•  Total points will give you a final score that will let you know your payment adjustment
• Measure Description     (All Claims based reporting will be available in HENO)

Current outcomes

• Functional Status change listed above
• If outcome is not available report high priority measure
  
  • Falls
  • Documentation of current medications
  • Pain assessment
  • Functional outcome assessment

2.       Promoting Interoperability Reporting Requirements (25% of Final Score)

         This is a requirement measure based on the honor system for a minimum of 90 days. These are things that are considered practice improvement

3.       Cost (15% of Final Score)

         No Data submission required. This will be calculated by the submitted claims

4.       Improvement activity scoring: (15% of Final Score)

•  Large practice (16+ eligible providers): 4 improvement activities for a minimum of consecutive 90 days (40 points)
  
  •    High-weighted work 20 points
  •    Medium-weight work 10 points
  •    Need one of the following combination
    • 2 high-weighted activities
    • 1 high-weighted and 2 medium-weighted
    • 4 medium-weighted
• Small practices (Fewer than 15 eligible providers): 2 improvement activities for a minimum of consecutive 90 days (20 points)
  •    High-weighted work 40 points
  •    Medium-weight work 20 points
  •    Need one of the following combinations
    • 1 high-weighted
    • 2 medium-weighted

Explore the Improvement Activities

Can you get Bonus Points?

• 2 points for each outcome and patient experience measure
• 1 measure bonus point for each other high priority measure
• Eligible:
  
  • Much have benchmark
  •  Case min requirement
  •  Data completeness 60%
  •  Performance rate greater than zero
  • Cannot exceed 10 percent of the total available measure achievement points
• Small practice bonus:
  
  • CMS will provide 6 measure bonus point in numerator as long as you submit data to MIPS on at least 1 quality measure

How Should I Submit Data?

• There are 4 ways participants can submit data:
  
  • Attestation in the QPP data submission system
  • Electronic Health Record (EHR)
  • Qualified Clinical Data Registry (QCDR)
  • Qualified Registry
• *Note: If you are a Large Practice (16+ eligible providers) you will have to use a registry.

Resources:

CMS: MIPS Scoring 101

APTA: MIPS Participation Overview