Seriously, do I need to do MIPS?
It's crunch time.
By Daniel Morrill, PT, DPT / CEO, President at TheraOffice
As the holidays approach, MIPS is lurking, and it could have a positive or negative effect on your rehabilitation business. At TheraOffice, we have done everything: read the final rule, been in discussion with national players in the quality programs, attended webinars, and yet there are still many reasons to be confused about whether or not a clinic or therapist should participate.
By the end of this article, I am hoping you will at least have the tools to make a justified business decision and help you evaluate participation. I am all about evidence, so let’s start with facts and not the notion that rehabilitation professionals should participate simply because in the third year of the MIPS program we were finally invited to sit at the grown-up table.
At TheraOffice, we initially looked at MIPS as another regulatory requirement for healthcare to ultimately control cost and decrease reimbursement. When we started to dig deeper, we found that it is a smart foundation for a program that is guided and influenced by people and groups invested in population health that could move the healthcare needle in a positive direction. With that, we opened our minds and started reading the rules.
MIPS is designed to collect data about healthcare. Granted, not all the measures will ultimately be meaningful to healthcare let alone physical therapy; but it is a start. The beauty of the program is that it is a capped monetary amount which means there are X amount of dollars for providers to divide up (the more providers with good scores, the less money they will receive). Some providers will do well, some providers will not do well, but at the end of the day, the providers that see the highest number of Medicare patients and have the best possible score will receive the highest payment adjustment. Keep in mind that payment for 2019 reporting will come in 2021.
So Where Do I Start?
The decision to participate in MIPS becomes an easy one when you have even a single provider that is considered to be required. With over $90k in Medicare allowed amounts and over 200 distinct patients, a provider becomes required and will incur a negative 7% payment adjustment in 2021 if they do not participate in the program. That is where you should start. The QPP site has a participation lookup tool that will end up being the ultimate authority on this, but this tool will probably remain outdated even into the new year. This leaves you with your practice management data to help you make the decision.
Rules of the Road
We’ve been doing the math on our side and here is what we’ve found:
- Any required provider needs to be participating in the program. Even at a minimum of $90,000 in allowables, a 7% penalty comes out to $6,300 lost in 2021.
- Be careful of buying into the possibility of a positive 7% bonus. This program was structured to be budget neutral, meaning the benefits only come from the losses. As this is the third year of the program, we have some historical data to look at. The maximum bonus in 2017 was 4%. After all data was submitted and scored, the percent bonus on a 100/100 MIPS score came out to be 1.88% or only 47% of the expected 4%. If the same trend continues this year, the true maximum bonus comes out to only 3.29%.
- Based on the expected incentives at varying MIPS scores, we recommend only enrolling providers with more than $65k in allowables. The same applies for group submission if your average allowed per provider comes out to over $65k. Anything short of this amount and you might find it difficult to recoup your costs.
Making the Right Decision for Your Business
The other side of the puzzle will be your expenses related to submitting data. As a software development company, we know developing and testing the systems that will collect, protect, submit, and report your MIPS data is costly. While using a registry might be more effective than claims-based reporting, providers will need to understand the costs associated with participating in a registry. Understanding your potential payment adjustment and expenses should ultimately determine your decision to participate. Ultimately, the decision is yours. Just make sure it is an evidence-based one.
It is also no surprise that EMRs and EHRs have a significant role in the MIPS program. The MIPS measures revolve around CPT and diagnosis codes as well as the need for specific documentation. Your system needs to be able to alert staff and make sure the proper data is collected at the right time, and it needs to start on January 1st for the 2019 reporting year. With that in mind, ask the questions, attend the webinars, and do the math. If you need help with the math or making a decision, we can certainly lend a hand. Ultimately, we are all in this together.
For more information on MIPS, visit our official landing page by clicking HERE!