For many of you who just learned that you will be required to participate in the Merit-based Incentive Payment System (MIPS), your head is now spinning on how to get yourself up to speed and ready for January 1, 2019.
You know from earlier this week that a clinician or group is required to report on 6 quality measures in which one has to be an outcome measure. The only patient reported outcome-performance measures in the Physical Therapy/Occupational Therapy Specialty subset are stewarded by Focus on Therapeutic Outcomes.
I have a feeling your gut reaction is that it doesn't seem reasonable for only one option for the patient reported outcome-performance measure to meet the outcome quality category. One change in this quality payment program is a true focus on quality. For physical and occupational therapists, benchmarking through a risk adjustment process is now incorporated to help determine the quality score. What will be reported requires two components: the patient reported outcome measure score and risk adjustment coefficients. Yes, this quality program is far more complicated than guessing the percent disability as with the previous requirement of functional limitation and severity modifiers.
You are in luck because the 7 MIPS Clinical Quality Measures (CQM) stewarded by FOTO have been endorsed by the National Quality Forum and CMS' quality payment programs (PQRS and MIPS) since 2008. The patient reported outcome-performance measures have been freely accessible since 2008. You have free access to exactly what you need to be able to report the required information.
So, now you are scratching your head. You know that FOTO measures are proprietary. What does proprietary mean? Proprietary means that the measures are owned, maintained, grown and continually developed. Measures that are not proprietary are of lower quality and of little real benefit. As you can see, it is important to use measures that have an owner and care-taker so that you can be sure they are continually developed and updated.
Although FOTO owns the measures, that does not mean you do not have access to them.
All the components needed to calculate a score are available for FREE for use by clinicians. You can find everything you need here. What isn't free is merging what you see for free into any other software without contacting FOTO about licensing.
The actual calculation of the FOTO MIPS CQM scores is complex. For those of you who are the do-it-yourself kind of individual, it is doable. It entails quite a few steps and some time to obtain and compile the needed information to produce the score to report. You would need to print out the short form of the patient reported outcome measure. After the patient completes the assessment, you would then need to use the scoring table on page 3 to score the patient's responses. You would also need to determine which risk adjustment variables to apply to your patient, find the relevant coefficients and apply them to the score calculation process.
Great news that there is a do-it-yourself opportunity, right? Reporting is a bit complicated also. Reporting for performance year 2019 may be different than your previous reporting experience. Only small practices (those with a tax identification number associated with < 15 National Provider Identifiers) are allowed to use Medicare claim submission type. The final rule had a nice visual that will save you some reading. (I hope the federal government doesn't mind me just copying and pasting it here!)
You need to consider which submission and submitter submitter type you will use. As you can see, if you are not considered a small practice, then you will need to consider various options for submission. The easiest submission process would include a submitter type that is a third party intermediary that submits directly computer-to-computer; this "end-to-end" type of reporting may result in bonus points. As mentioned earlier, FOTO is a Qualified Clinical Data Registry and can submit your measures in an end-to-end mode.
Keep in mind that you will have some wiggle room when it comes to the completeness of your data submissions. The requirement is to submit data on at least 60% of your patients.
I know the FOTO team has been reviewing the Final Rule and are making preparations to assist MIPS eligible clinicians to meet the quality indicators. I'm sure you'll hear more from FOTO in the upcoming weeks.
Until next time,