Quality Matters: A beginner’s guide to MIPS

If you’re like most physical therapists, three things are likely true when it comes to your knowledge about MIPS.

One, you know that MIPS is the Merit-based Incentive Payment System, a value-based initiative that is part of Medicare’s Quality Payment Program (QPP). You’re also probably aware that MIPS is a big deal—that participation is becoming mandatory for many, and that it’s likely you’ll have to participate as well. And finally, there’s a good chance you’re wondering what MIPS can actually do for your practice. Will it help you financially? Care-quality-wise? How are you really supposed to know?

To find answers to those and other important questions, we talked with several physical therapy practices that are already taking part in the program. What we learned is that it’s easy to get started in MIPS, and that doing so now will pay dividends down the road.

MIPS 101

First, an explanation of what the program is all about. Created under the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015, MIPS provides a payment adjustment for Medicare Part B services delivered during a given “performance year.” Clinicians participate in the program either as an individual or through their practice, and their adjustment is based on how they do across a number of different performance categories. Participants report their results in each category (either through the QPP portal or a third party like a Qualified Clinical Data Registry), and Medicare calculates a “MIPS final score” that determines whether the adjustment is positive, neutral, or negative.

Only two performance categories—“Quality” and “Improvement Activities”—apply to PTs and PT practices participating in MIPS in 2020. The Quality category measures healthcare processes, outcomes, and patient experience, and is weighted to account for 85 percent of the MIPS final score. The Improvement Activities category, on the other hand, assesses work focused on improving clinical practice. Among the initiatives that qualify under this measure: efforts to follow-up on patient-experience and -satisfaction data, and work related to improving processes for developing individual care plans.

Important to note is the fact that payment adjustments are applied to payments for services provided two calendar years after the performance year. So a physical therapist who reported through MIPS in 2020, for example, wouldn’t see changes to their Medicare payment rates until 2022. Also good to know is that beginning this year, Medicare is offering a streamlined reporting framework called the “Alternative Payment Model Performance Pathway,” intended for those who participate in APMs. And starting in 2022, if all goes as planned, the agency will launch yet a third reporting framework called “MIPS Value Pathways,” or MVPs.

Should you participate in MIPS?

Some PTs and practices have no choice; based on the business they do through Medicare, their participation is mandatory.

You most likely must take part in MIPS if you…

1. Bill more than $90,000 for Part B covered services, and
2. See more than 200 Part B patients, and
3. Provide more than 200 covered services to Part B patients

If participation isn’t mandatory for you or your practice, you can still opt-in to the program if you exceed at least one of the three low-volume thresholds listed above. Which begs the question: Why would anyone choose to opt-in to MIPS?

“For us,” says Janie Taylor, PT, CPT, OCS, Chief Executive Officer with Physical Therapy Central in Oklahoma, “opting in was a quality decision, but it was really a business decision as well.” Because the practice is tracking quality measures, she explains, its therapists are now keenly aware how things like patient engagement in and out of the clinic can help drive better outcomes. And from a business perspective, participation just made sense: The experience they gain in MIPS will help them succeed in any other value-based program they sign onto in the future; and the potential for bonuses is especially appealing in light of recent cuts to Medicare’s fee schedules. “A big part of this is definitely financial,” Taylor says. “We’re very mindful of the payment incentives tied to MIPS.”