The Centers for Medicare and Medicaid Services (CMS) has proposed changes with the 2019 Merit-based Incentive Payment System (MIPS) for payment year 2021 that will impact rehabilitation clinicians.
CMS released the preliminary 2018 Proposed Rule "Medicare Program, Revisions to Part B for Calendar Year 2019, the Shared Savings Program Requirements, the Quality Payment Program and Medicaid Promoting Interoperability Program". The Proposed Rule included adding physical and occupational therapists as eligible clinicians for the 2019 MIPS performance year (2021 payment year). You can find all 1,472 pages here. I haven't fully read the document because it is so darn long. In skimming it, I found a few things in which you all need to be aware.
The biggest proposed change for MIPS that affects rehabilitation providers is the inclusion of physical therapists, occupational therapists, clinical social workers and clinical psychologists as newly added eligible clinicians. There may also be additional eligible clinicians added. These include: qualified speech-language pathologists, qualified audiologists, certified nurse midwives, and registered dietitians or nutrition professionals. The inclusion of the additional eligible clinicians is dependent upon the number of quality measures specifically available for them. If there are not six MIPS quality measures available to them they might not be included as MIPS eligible.
If you find yourself now included as MIPS eligible, it gets a bit tricky. You may actually be excluded; you may be able to opt-in, voluntarily report and not participate; or you may be required to participate. By opting-in, you agree to a positive, neutral, or negative MIPS adjustment. By voluntarily reporting, you remain excluded and receive no MIPS adjustment, but you get the chance to do a trial run and find out how ready you may be to participate next year. The reporting can be at the individual clinician level, a group level or even a virtual group level. Your options for determining the type of participation available to you are dependent upon 3 factors. These factors include the number of Part B patients treated by the clinician or facility, the number of professional services provided and the amount of Medicare payment. The proposed rule has a cute little table that explains the low-volume determination threshold so much better than any words.
In reviewing the document, the calculation of the number of beneficiaries, dollars paid and covered professional services is based on claims data. For 2021 payment year, it's kind of weird how the determination is going to be done. The proposed change for the 2022 payment year makes more sense (January 1, 2020 - December 31, 2020). But, for 2021 payment year, it's really confusing to me. It seems two chunks of data are used: from October 1, 2017 through September 30, 2018 and from October 1, 2018 through September 30, 2019. I don't quite understand why it is broken up into two chunks of time. If this site remains active, you can input your National Provider Identifier to determine know your participation status by performance year. However, since it is not known how soon CMS will be able to have your information ready to officially determine your 2019 status, you might want to take a run at estimating your own numbers based on the thresholds shown in the table above to get an idea ahead of time.
For the proposed new eligible clinicians, there is no requirement to report on the Performing Interoperability (PI) category during 2019. CMS is inviting comments on the PI category.
For the proposed new eligible clinicians, the cost performance category weights will continue to be considered and CMS is inviting comments.
The new eligible clinicians will be required to report on improvement activities. The proposed rule indicates that those activities are acceptable for this group of new eligible clinicians.
The Proposed Rule shared the specialty measure set of quality measures for physical therapists and occupational therapists on page 1403 - 1406. The proposed quality measures are very similar to the previous Physician Quality Reporting System (PQRS). The proposed quality measures are of two measure types: process and outcome. Process measures comprise the bulk of the specialty measures. The measures address fall risk, body mass index, documenting current prescribed and over-the-counter medications along with supplements, assessing pain and addressing pain, and assessing function. The list of outcome measures for physical therapists and occupational therapists only includes seven NQF endorsed patient reported outcomes measures that are stewarded by Focus On Therapeutic Outcomes, Inc. (FOTO). Explore outcomes measures in this CMS tool. Eligible clinicians opting-in, voluntarily reporting and required to participate will need to report on a minimum of quality measures.
More good news contained in the Proposed Rule was removal of the functional Limitation Reporting (FLR) requirements for rehabilitation providers after January 1, 2019. This means therapy providers would no longer be required to submit the functional limitation G-codes and severity modifiers to CMS.
I know the FOTO team has been reviewing the Proposed Rule to best determine how to help the eligible clinicians to meet the quality indicators. I'm sure you'll hear more from FOTO in the upcoming weeks.
Until next time,