Now that you have had time to read the final rule or various blog posts and news releases across the internet, if you are required to participate (or are choosing to opt-in), you need to decide which reporting option is best for you.
You know from earlier this month that physical therapists and occupational therapists are now considered MIPS eligible clinicians. These groups or clinicians all have a national provider identifier and bill for Medicare B services. Although the MIPS program consists of 4 categories: quality performance, cost performance, improvement activities performance and promoting interoperability performance, for reporting year 2019, only quality measures and improvement activities are required to be reported. Because only 2 categories will be reported, quality measures will be weighted at 85% while improvement activities at 15% of the total score.
As a business owner, I have been wrapping my head around the options available to report the required information.
To me the best option is to use a registry. I already know that although I could report via claims that using that option will be problematic. From my experience in the past, the only way to send data via claims is if a service was actually provided and billed. I don't know about the rest of you, but when it comes to having complete sets of data with regard to the outcome of care, patients may not necessarily attend on their last scheduled visit. I can easily get the patients to complete a patient reported outcome measure, the problem resides in reporting the functional limitation and severity modifer. (Okay, I know this goes away for 2019, but I need to rely on history and my experience as I think of the changes for 2019.)
I also know that logging in to report information is definitely a no-go. First, I would need to have my EMR create a report that contains all the information that needs to reported. (And then I would have to merge that with my FOTO data for each patient.) I would then need to figure out the best workflow to actually log in and report. From my previous experience in creating a database, the likelihood of data entry errors is high (I'm known to transpose numbers at time) and the types of mistakes I make could be detrimental for my business. At the same time, there is nothing worse than sitting for long periods of time doing the tedious task of manual entry. And then, I am cringing at the number of passwords and the type of allowed passwords and the frequency of changing a password that will be required. If this aspect is anything like what I experience with C-SNAP (the option I have with Wisconsin Physician Services, which is Medicare B payer for Michigan), I don't think I can keep up with the password situation that will be required. On top of that, if there is a required email authentication code after I already believe I am logging in, then I'm even more irritated. Lame, I know, but being required to frequently change passwords and then going to an email to copy and paste an authentication code really irritates me.
There are two types of registries from which to choose for reporting.
Qualified registries: These registries are required to report the MIPS measures in the quality category. The Physical Therapist/Occupational Therapist Specialty Subset of measures include: body mass index, medications, pain, function and the functional status change measures stewarded by FOTO. Because this is a registry, it is highly likely that this registry will be a direct submission. A direct submission is considered to be end-to-end reporting.
Quality Clinical Data Registries: These registries have apparently been vetted by Centers for Medicare and Medicaid Services. The quality measures may include measures that do or do not include the specialty subset. The measures in the clinical data registry are considered relevant to the profession. These registries may also continually add even more relevant measures as CMS approves them.
What do you need to know before making a decision when choosing a registry?
It would be great to have a compare and contrast type of table comparing the various registries. You need to know your typical Medicare payments. You can then use that to calculate potential gains from MIPS participation. The gain needs to be offset by the cost to use a registry. When you ask about cost, you need to know set-up fees, supportive service fees, monthly fees for organization or therapist or both, and any additional fees (such as per item reported or even connecting to the registry if using say your electronic medical record with another entity).
First of all, you need to know if the registry reports both the quality and the improvement activities categories. I don't know about you, but I prefer the easy button. I'd rather not have to create an online account to log into to report improvement activities. Do not assume that a registry will report everything that needs to be reported.
Next, you need to know exactly what the registry reports. For me, the quality category is now much different than all the previous years reporting. In previous years, we all had the exact sets of data we were reporting. Every patient had the exact same measures reported. Now, this quality payment program appears to have a lot more flexibility within it. What will the registry report? Will you be able to ensure your processes allow you to capture the necessary information to consistently report?
I don't know about the rest of you, but I would categorize myself as lazy in certain aspects of my life. I prefer to take the easy route when it comes to documentation and any requirements that are not directly face-to-face with patients. So, you need to ask with any registry, how does the registry acquire the data? Once the registry is set up are you on autopilot or will you be required to intervene with manual data entry?
I know I would want to control the frequency of my reporting. Can I determine when data is submitted or does the registry control the timing of data submission?
Since I am a Medicare B provider, the next area of my concern that requires some answers is a bit more complicated. My interpretation of the final rule makes me believe that in order to meet the reporting requirements that I need to report on 60% of my patients. All patients - not just Medicare B beneficiaries. (Now, I don't quite get this because to me, it doesn't seem reasonable that CMS acquires data on all patients, but for registry reporting, it seems all patients require data reported.) From a mathematical perspective, a group NPI that has more than 15 therapists seems to have a bit more wiggle room for error, possibly. For someone like me though, I have to make sure that every patient has data. I don't have the high volume to offset missed data points. Now, it probably isn't difficult to attain data for all the process measures because those measures are very similar to Physician Quality Data Reporting of the past: body mass index, pain, medications, function. When it comes to the benchmarked data consisting of outcomes, predicted scores and the risk-adjustment coefficient calculations, I believe this area becomes more tricky. What I mean is that if I am treating someone who has had a total knee arthroplasty, well, that patient will not have functional status change reported for the cervical spine, but better have functional status change reported for their knee. So, I need to make sure that I have the outcomes data for at least 60% those patients, along with what I believe would be helpful, a tally of how many patients treated and reported for a general orthopaedic condition, a foot/ankle condition, a knee condition, a hip condition, a lumbar spine condition, an elbow/wrist/hand condition or a shoulder condition.
A registry can "guarantee" you pretty much anything it wants. You have to realize, the guarantee will have limitations. If you don't meet the 60% reporting requirement, you will fail. A registry cannot guarantee that you will capture the required data for 60% of your patients. Your processes and work flows are key components to ensure that you consistently capture every piece of required data for every patient that receives services from you.
As I dream about the utopia situation to help me be successful in reporting, I believe I would need a dashboard. Registries should be able to provide you some sort of feedback. The next line of questioning that I believe you should ask of registries before you choose one is about a dashboard.
SUBMISSION DATE: Will the dashboard provide a date stamp of when data was submitted?
SUCCESSFUL REPORTING: Will the dashboard indicate the data was submitted successfully?
INFORMATION ON EACH MEASURE: Will the dashboard provide information on each measure? Will the dashboard indicate the total number of patients that should have had the measure reported and the percentage of the patients that had the measure reported?
NUMBER OF CASES REPORTED FOR EACH MEASURE: Within the final rule, if I recall, 20 cases per measure were needed. It would be great to see a tally count of how many patients have the measure reported. A tally of how many patients treated and reported for a general orthopaedic condition, a foot/ankle condition, a knee condition, a hip condition, a lumbar spine condition, an elbow/wrist/hand condition or a shoulder condition would be helpful.
Last week I learned that the FOTO Team will have a few upcoming webinars. You might be interested in learning more from the team and how FOTO can help with MIPS reporting.
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,