Last week the Centers for Medicare and Medicaid published the final rule for Merit-based incentive payment system (MIPS) and alternative payment model (APM) incentive under the physician fee schedule.
With MIPS, one huge point to remember at this time: physical therapists, occupational therapists and speech language pathologists are not MIPS eligible at this time. Physical therapists, occupational therapists and speech language pathologists may voluntarily report measures and activities (without any MIPS payment adjustment). Since CMS always evolves, it's good to know what's changing and how in order to be prepared for the future.
MIPS reminds me of meeting Michigan physical therapist re-licensure requirements: categories and items within each category. MIPS is comprised of 4 categories of which three are weighted. Only 3 will be active in 2017 and all 4 in 2018. The category with the least information = "cost." I will assume that category will be defined at the end of 2017. For 2017, three weighted categories will be rolled out for MIPS eligible clinicians: physicians, physician assistants, nurse practitioners, clinical nurse specialists and certified registered nurse anesthetists. The categories are: Quality (weighted at 60%), Advancing Care Information (weighted at 25%) and Improvement Activities (weighted at 15%).
Quality: Quality has characteristics similar to Physician Quality Reporting System. There is one definite change. Along with reporting 6-15 process measures, an outcome measure is also required. Rehabilitation providers will have no difficulty reporting an outcome. When I filtered the search for outcomes, there were 8 options available for reporting outcomes. Seven of the options were FOTO measurement tools. The outcome measures listed with CMS for rehabilitation providers: general orthopaedic impairment, elbow, wrist or hand impairment, foot or ankle impairment, hip impairment, knee impairment, lumbar impairment and shoulder impairment.
Advancing Care Information: This area appears a bit confusing. For 2017 there are two tracks of options from which to choose. Since rehabilitation providers are not eligible clinicians in MIPS 2017, my focus will be on the other track. This area has 15 items to meet. Rehabilitation providers will not be able to meet all 15 - a few of the items are physician-specific. If I were to sum up this area, it seems to be focused on the efficiency and usability of health information technology. For rehabilitation professionals think: secure messaging to patients.... submitting clinical data to a registry... allowing patient access into health portals (to view, download and share information)... using technology for patient education... telehealth... and easily sending and receiving information electronically. The odd aspect in this area: the description often includes the phrase, "for at least one unique patient seen by the MIPS eligible clinician." It's kind of odd to have such a low standard for an area that does seem quite important. Although, if I look at secure messaging, how can one put a number on it? The main point is that secure messaging is available. This category will make you dig into your health information technology (HIT): your electronic medical record, your home exercise programs, your outcomes management system. You'll need to know if you can use your information technology in ways to meet advancing care information. Reach out to your HIT companies to see when they will be able to meet the items in this section.
Improvement Activities: At first glance this area appears quite daunting. The fine print indicates that the number of MIPS eligible providers you have determines whether you attest to 4 improvement activities or 2 improvement activities. The word used: "attest." As I looked through the long list and clicked and read the descriptions, you can make this as easy or as difficult as you'd like. Some of the improvement activities will help you grow your business. Improving health status in communities and having a standard program of maintaining contact with patients who have ended an episode of care are not only good for Medicare beneficiaries, but also for your business. Engaging patients and focusing on increasing self-efficacy are two areas that improve your outcomes. Motivational interviewing (as an option mentioned in the description of one activity) is great for changing behaviors. FOTO can help with four items: Collecting data on patient experience and satisfaction and implementation of formal quality improvement methods. Feedback on your services and continual quality improvement help to increase word of mouth. FOTO helps engage patients in their plan of care with its patient specific report and the optional Patient-Specific Functional Scale. FOTO may be an acceptable solution for promoting the use of patient-reported outcome tools. This category is only weighted at 15% and could actually have the greatest ripple effect for some of the possible items.
FOTO can definitely have a large role in meeting the requirements in 2 MIPS categories: quality and improvement activities. If you are searching for a product that will help you be prepared for the future, please talk to Judy Holder. FOTO can definitely be a solution for you.
If you'll be at the 2016 PPS annual conference, please stop by Booth #315 to talk to the FOTO team about your needs. FOTO does far more than help meet MIPS.