MIPS Made Easy with TheraOffice
Hi everyone, this is Andrew from TheraOffice. And I wanted to welcome everyone to today’s webinar myths Made Easy with TheraOffice before we get things started. We just wanted to pass along a couple of notes a copy of today’s Slide show presentation will be emailed to all attendees shortly after the conclusion of the webinar this afternoon.
In addition everyone will also receive a recorded version of the presentation by this Friday. If you have any questions throughout the webinar, feel free to submit them through the Q&A panel at the bottom of your screen. We will be answering as many questions as possible at the end of the presentation with that.
I would like to pass things over to our director of product management Nick Austin who will be presenting today’s webinar. Thanks again for joining us. Thank you, Andrew. Hello, everyone. Welcome to today’s webinar It’s Made Easy with TheraOffice. My name is Nick Austin and I am the product been director of product management here at Hands-On technology as I go through the list of people in attendance today.
I noticed a lot of familiar names names that have been in attendance on previous webinars for evaluation code updates for ICD-10 for function reporting for pqrs. Today. We’re here to talk about the merit-based incentive payment system or mips. Without question. This mips represents the most complex change pts have faced in the past decade our goal today is to make it easy, but we will settle for easier with that being said, let’s Jump Right In So to avoid confusion.
We waited until now to mention this our presentation on maps will consist of two separate webinars. Unfortunately, there was just too much information too crammed into a single session. Today’s webinar will be discussion of the program as a whole will help you make the decision as to your level of involvement in that program.
Should you decide to participate the next webinar will be focused on the details of the measures. You will need to complete just like this webinar. The next one will be recorded So if the day and time do not work for you know that it will be available in the training center. You can sign up for that additional webinar by clicking on the link in the attached PowerPoint in today’s follow-up email or by visiting our website.
Let’s start with a little bit of background in 2015 Congress passed the Medicare access and Chip reauthorization act or macro. The purpose behind macro was permanently resolved the sustainable growth rate or sgr problem. For those who are not familiar sgr was impending Medicare cut that would grow every year and every year it would be postponed in 2015 that cut was permanently repealed but replaced with some additional regulation in the form of the quality payment program or qpp.
The purpose of that regulation was to move the healthcare industry towards interoperability and paper performance. Overtime Healthcare Providers would have two options participate in alternative payment model or enroll in the merit-based incentive payment system or mips. Miss was structured as consolidation of existing incentive programs pqrs meaningful use and value-based modifier as with all be combined into a single program that would aggregate the scores from each to produce a single composite score this Mabe score positively or negatively impact your Medicare reimbursement for future years.
In 2017 the program officially began and initially pts and OTS were excluded from the program entirely. You could submit data if you wanted to but your Medicare reimbursement would not be impacted in any way by Maps then after much debate. It was decided that PT is no cheese would be brought on board with the 2019 reporting year.
Participation level within mips is a complicated subject can really be broken down into three categories those who cannot receive a payment adjustment or exempt from the program those who can optionally choose to report and those who must report or else they face a penalty. Let’s start with those of you that are exempt.
As of a few weeks ago speech language Pathologists were not included in the program. Then with the release of the final rule, they were included at the very last minute. So to be clear as of right now speech language Pathologists will need to participate in the program the same as pts or OTS. They will go through the same determination period check the will be going over in the next slide.
Because of this last-minute inclusion and because they are not part of any existing specialty set slps involvement is still a little vague. We should have more information in time for the next webinar where we start talking about specific measures. So moving on to our next exception if you submit institutional claims to Medicare you are exempt from the program when you submit institutional claim the provider that actually rendered the service is not included on the claim.
Without this information Medicare has no idea who they should involve in the program if they do not have any data related to that individual provider. We did start to see some information on lips related to facility based clinics. So I would expect their inclusion in a future year. If you are submitting institutional claims with still pay attention to the program closely as it could be in your future.
New providers and rolling into Medicare for the first time in 2019 are exempt from the program as well as anyone participating in advanced alternative payment models. If you are not sure if you were in an advanced a p.m. Or not, you most likely or not. There are plenty of issues out there Petey’s but there are special requirements that a CEO that is going to be mips exempt.
The last piece deciding your involvement is based on results of the determination. For this let’s move to the next slide.
CMS will determine your options for enrolling into the mips program using what they call a determination period for the 2019 reporting are there to determination periods with one of them. Just coming to a close? Close the first period runs from October 1st 2017 to September 30th, 2018. The second runs from the same time frame one year later.
CMS will determine your level of eligibility for the mips program based on whether your individual and Pi meets. The threshold seen here during both determination periods, 200 units 202 stinks patients and $90,000 in allowables. If you exceed all three thresholds, you will be required to participate in the mips program or else you will receive a penalty.
If you have seen one or two thresholds, you will have the options of option of participating doing so will open you up to the potential of a penalty but it will also mean that you cannot receive or that you can receive a positive payment adjustment. If you do not meet any of these thresholds, you are not considered to be missed eligible and cannot opt into the program by yourself more on that later.
As long as you are regularly treating Medicare patients, you’re probably going to exceed the unit threshold. This one was actually added this last year and was done for the sole purpose of allowing more providers the option of participating in the program. The other two thresholds are much harder to meet seeing 200 distinct Medicare patients through a one year time span will usually come down to your paramedics and to your company’s policy of rotating patients between providers.
If a patient coming into your clinic sees only a single provider it might be unlikely that you meet the patient threshold meeting. The allowable threshold is again dependent on that pair mix majority of providers will not meet all three and fall in the category of this being an optional program.
That being said it is critical that if you do meet all three, you’re aware of your requirement to participate in this program. The reason for this has to do with incentives.
If you were familiar with how pqrs incentives work, you have a bit of a head start. It’s incentives and penalties are done through a payment adjustment two years after the reporting year. There are no checks that get sent in the mail is simply an adjustment made to the allowables in that payment year.
Starting January first will participating in the 2019 reporting or performance year. This will have implications in 2021 which will be known as the 2021 payment error. If participating in the program your payments in 2021 will be impacted by your score in 2019. While pqrs paid for simply reporting mips pays for actual performance.
It is not enough just to report that you didn’t record the BMI of the patient. You actually have to record that BMI and tell Medicare you recorded it to get. Each participating provider will receive a score between 0 and 100 and their payment adjustment will be on a sliding scale based on that score in the next few slides will be going over what that scoring looks like, but there is one more piece.
I want to mention before we get there. Payment in mips our budget neutral this means that the providers at the top of the performance Spectrum will receive a positive payment adjustment based on how much money is subtracted from the providers at the bottom the exception to this comes with the exceptional performance bonus.
This is a pool of money that is allotted by CMS to go to the very top performing providers in the program regardless of budget neutrality. Now, let’s take a look at the breakpoints are in the 2019 reporting year.
Here you’ll see a breakdown of what the final scores mean for 2021 payment adjustment starting at the bottom is the zero to seven point five point range. Providers falling into this range will receive a negative payment adjustment of 7% If you remember back from pqrs the maximum penalties each year for not participating was only 2% This bottom tier is arguably the most important Point behind this entire webinar if during the termination period your flags being required provider you were looking at seven percent penalty.
Should you ignore the program in its entirety? Next I want to call attention to the 30 point marker for the 20 2019 reporting year 30 minutes points is the threshold that you must meet to guarantee you receive a neutral or positive payment adjustment. If you’re going to participate mips 30 points should be considered your absolute minimum fall below a or C of a a negative payment adjustment somewhere between zero and seven percent.
Above and you will start to see a positive payment. Given the nature of budget neutrality I would caution optimism on the payment adjustment in the 30 to 80 Point range being that much if you’re really looking to hit a home run with maps you want to fall into that top tier scoring above 80 and 80 points the exceptional performance bonus kicks in.
We won’t know for sure what these exact percentages look like until 2021 after CMS has started to calculate the payment adjustments. However, because we’re coming into the program two years late. We do have some additional Insight based on what happened in 2017.
Advisory.com put together a really nice article that analyzes the payment adjustments from the 2017 reporting year during that year. The maximum estimated penalty was set to 4%. The same goes for the positive incentive the exceptional performance bonus in reality the provider scoring at top-end nib score of 100 received only a 1.88 positive payment adjustment.
This means that there were a lot more successful mips providers than unsuccessful. This is expected to continue into this year as well though, the impact of including new mips eligible clinicians is currently unknown. Based on these figures one could assume that the max incentive for the 2019 reporting your might approach four to five percent not the seven percent that is sometimes quoted but still a significant opportunity.
So let’s look at this with a little more granularity advisory dot-coms article also includes a breakdown of every mips article or mips core and what it meant for a payment adjustment back in 2017 with the program being brand-new. The neutral point was only three points compared to 30 points in 2019.
The important piece I want to note here is the DraStic jump that happens at the exceptional performance bonus mark. In 2017. This was at 70 minutes points from their each additional point is were significantly more than it was before that point. So what does this all mean? If you’re going to participate in the Mist program?
I was just one of two goals either participated the minimum making sure to hit that 30-point Mark or go all out trying to max out at a hundred while those last few points might be difficult to achieve. They really start being worth it. Once you get into the exceptional performance bonus.
Alright, so now that you’re familiar with the concept of the program and what is at stake. I want to now briefly go into the actual categories of maps and which of them will be impacting your clinic. Like I previously mentioned the next webinar will go into detail on the relevant categories and measures so think of these next few slides is a preview for that webinar.
The four categories of maps are cost promoting interoperability quality and Improvement activities.
Let’s start with the cost category. This is a rehash of an old program known as the value-based modifier in it CMS would analyze your claims data to determine how cost effective your clinic was being? As cost treatment is not nearly the issue for pts as it is for Physicians. We have always been left out of this program.
This extends to mix as well pts OTS and slps will not be participating in the cost category of mips and therefore will have this category waited to zero for their final scoring you will not be penalized for not being in this category is simply not included in the equation for calculating your final score.
The same goes for promoting interoperability category of MEPS. This category was previously known as advancing care information or meaningful use meaningful use has long been the biggest incentive program in health care and it never fully went away was simply rolled up into the mips program. The purpose of this was to get everyone using EHR technology in a meaningful way.
These ehrs had to be certified in various areas to ensure their compliance with that program such areas included e-prescribing and patients having access to their documentation through a portal whenever you hear the term certified EHR or simply a needing certification. It is entirely for the purpose of this individual category.
This is the main reason to get certified just like before pts. OTS and slps are being left out of promoting interoperability with that exclusion. There is no myths related reason for TheraOffice to be certified know too that if we were if that were ever to be the case, we would go through that process of getting certified in the necessary areas.
The third category is quality, which is a direct Port of the old pqrs program. As we have participated in picaresque before so will we emit is the category of the quality category consists of a collection of various measures to improve the quality of patient care. The good news for pts. Is that the measures in the quality category that you will be reporting on are all very similar to what you saw in pqrs.
The specifics of these measures will be covered in detail in the next webinar for Now quickly. Wanted to go through what measures are there.
Here you will see a list of the measures from the PT OT specialty set in the recently released final rule. The first four should be familiar to anyone that participated in pqrs. BMI screening current medications pain assessment and functional outcome assessment are all part of the measure set for pts one additional change that came through with this recent physician fee schedule final rule was that functional limitation of reporting as a program is being phased out on January 1st for Medicare insurance has more on this in a later webinar, but I bring it up for now for a specific reason.
Well, that’s always going away. The need to have patience take standardized functional outcome assessments is not going away just because we’re moving away from flr codes does not mean we are moving away from outcomes the exact opposite actually in addition to the functional and pain assessment feed measures.
This is this specially set also includes seven measures for functional status change. We’re tracking the risk-adjusted outcomes for your patience. The purpose of the mips program is to put providers down the path for paper performance tracking your outcomes and submitting. The results Medicare is an essential piece to that.
The final category of mips is brand-new Improvement activities is the second required category for pts. OTS and slps this category carries less weight in the final scoring and quality, but it is still important for anyone pursuing the exceptional performance bonus. The category itself is a much less rigid structure to it.
And for that reason we expected to be a popular one amongst providers simply put you need to perform an activity over a 90 day period and then a test to CMS that you performed. No, data submission or documentation directly addressing the activity furthermore. There’s significant overlap between the Improvement activities and areas you might already be addressing.
So let’s go through some examples. Here, you’ll see a list of a PTA suggested Improvement activities. These were a total there are a total of 113 activities in 2018. And you’re technically eligible to any of them. The list here is a subset that might be more relevant for PTS. The first activity mentioned here is a highway and it’s simply to promote the use of patient reported outcome tools.
You’re already using an outcomes tool to submit on the functional status change measures. You could also test to completing that Improvement activity. No additional work required. You are already doing it. This goes for quite a few of these. The other one. I want to draw attention to is highlighted at activity on patient satisfaction in q1 of 2019.
TheraOffice will be releasing a patient satisfaction survey tool available right from within TheraOffice. Utilizing that tool for a 90-day period in 2018 will allow you to attest to that Improvement activity as is the case with the quality measures. We were doing a deeper dive on the specific Improvement activities in the next webinar.
At this point you might be feeling a bit overwhelmed simplify things a bit. We suggest focusing on three decisions. In the next TheraOffice update you’ll be required to go through a mix wizard where you are guided through these three decisions think of this as a preview for that update. The first question is whether or not you are participating at all during that update.
We will be querying your database to mimic the determination period calculations made by CMS. This should add some insight on who is required to participate. Participation in the program is big decision for your company. There are certainly situations where clinics would serve the best interests by not participating in mips.
But in general we are recommending participation. There is the outside chance of repeal, but the more likely path is an increased involvement in mess with each passing year furthermore not be getting easier. Threshold will be dropped and the maximum penalty will be increased each year 2020 will be nine percent 2021 will be 11% misrepresents the best opportunity opportunity.
You have to increase your Medicare reimbursement getting into the program now and excelling at it will be the best path for many providers. Should you decide to participate you have to decide how you will be submitting that data. Your choices are either claims or registry? Then you have to decide between submitting individually or as a group.
So let’s explore these last two questions with a little more detail.
If you submitted pqrs with TheraOffice and previous year’s you did so using claims. We never offered an alternative that was because we felt strongly in the claim submission as the best option as you probably should have expected by now. It is a little more complicated. Let’s start with one of the most important changes in the mips program.
And that is the limitation of claim submission to only small practices small practice is defined as having 15 or less providers attached to your tax identification number during the those previously mentioned determination periods. We are over 15 providers. You cannot submit your mitts data through claims and will instead be forced into using a registry for your submission.
So when it comes to making a decision on this part, this really is only a decision for small practices. The biggest difference between claims and registry submission has to do with the scope of the program when submitting claims data, you only need to complete the mips measures on Medicare patients and submitting to a registry you required to perform the quality measures on all patients regardless of pair type.
If you took part in pqrs, this is new. That program was limited to only Medicare patients while registry submission in mips extends to all patients or registry also comes with a cost an additional outcome measures you are expected to report on with all that being said you might be asking yourself.
Why would I ever choose a registry over claims? For small practices making this decision. I would look at your experience with pqrs never participate in that program before or maybe you did but did not have good results. It might be a good idea to consider registry as an option even as a small practice you will be paying for registry, but it will in turn work with you on ensuring your success in that program.
They will offer quarterly status reports and work with you on Data completeness before the data is actually submitted to CMS. There are less surprises associated with the registry. If you are small practices, he’s a tremendously high percentage of Medicare patients and the mips program poses a high potential risk for your company and listening the services of a registry to ensure success might be a really good idea.
The last reason to use a registry is to start familiarizing yourself with something that will become standard in upcoming years with every passing year CMS has been pushing the healthcare industry away from claims and closer to electronic reporting small practice were given a reprieve for now, but it might not last long CMS has been very clear in their desire to get everyone on the same method of electronic reporting with a registry being the best option for outpatient rehabilitation.
With all that in mind the next slide shouldn’t come as too much of a surprise. I’m happy to announce today that we have been approved to be a qualified registry in the 2019 reporting year to ensure all of our users have a shot at successfully reporting in maps therapist is getting into the registry game we have.
We will have additional information related to the registry including pricing information and sign up details as soon as they become available. If you are interested in receiving more information related to the therapist registry, please answer. Yes to the pole that Andrew is putting up now and we’ll give it a second here while everybody gives in their answers for this will make sure to keep your contact information on hand for when these details are finalized and communicate to you the next steps.
All right, we got most of you. I think there’s a few people might have fallen asleep. That’s okay. I understand nips is not the most exciting thing in the world for everybody. So if you fell asleep, maybe you can wake up at some point and get back to us on whether or not you’re interested in the registry.
So the last decision to make is whether you want to submit individually or as a group this relates to how you want your data be looked at by CMS. Do you want them to assign you a mid score on each individual provider or do you want them to aggregate your scores across your entire 10 another way, I would look at this question is to ask yourself how many providers you will want to participate in the.
Let’s assume you are a practice of 50 providers. You see minimal Medicare patients. So turns out that none of those 50 are actually required to participate in the program. However, you want a small handful of your most experienced providers to participate essentially getting your practices feet wet with regards to maps for this Clinic.
The only one to involve certain providers individual submission is best for them. Let’s imagine that same Clinic decides that every provider should participate in that they should be jumping headfirst into the program. They can choose to submit as a group and the total result of the composite scores will be with impacts every providers payment adjustment in 2021.
Submitting as a group is also how you get around certain providers not meeting any of the determination. Thresholds. As long as you’re submitting as a group, you need to meet those thresholds across a some of the entire group. If you have a varying Medicare mix across your providers group submission is probably the best option.
So in addition to becoming a registry in 2019, TheraOffice is also releasing an update before the end of the year that will solidify our mips offering if you did pqrs in previous years you remember the picaresque questionnaire. When locking a note we would ask you which measures you completed and what you did for each of them with mips will be taking the PT measures and building them directly into the documentation.
For example, we are adding a new BMI section that is preview here. You’ll be indicating your patient’s BMI directly in the section and then given options for your follow-up choices based on what you do in this section. We will automatically select the appropriate mix measure at the bottom for you.
Furthermore we are building into the mips setup wizard the option of requiring participation on every patient. They should lock down the system and force your providers into meeting the requirements on every eligible note before that note is locked. In the next webinar, you will see more previews of these changes then before the actual release of the software will be doing one more final webinar that will directly address all of these changes in the next update.
This includes changes unrelated to mips like an upgrade to the spell check system that we think providers will like Andrews going to put up one more poll. Now that asks whether or not you should be or you would be interested in being in the beta for this that 11. If so, we will contact you as soon as that update becomes available for beta testing.
This is going to give it another minute now. Well, you answer that poll. All right, so I thought it might be best to finish up with a timeline before the end of the year. We will be releasing the data 11 update for both on-site and web. We are currently planning the rollout to start at the beginning of December while ensuring to update the last clinic by December 31st.
That day will also be the last day you can sign up for the therapist registry that on January 1st flr will get phased out. You will start collecting data in TheraOffice on the various mips measures on April first register users will receive a status update on how they are doing with MEPS. These quarterly reports will continue until the end of 2019 where the reporting period officially will.
What you want to 20/20 Registries will need to submit their data on behalf of the clinics to CMS. All right. Thank you everyone for attending today’s webinar whether or not this was brand new information to you. We hope you found it was helpful in some way. Please feel free to submit any questions you have you will do our best to get them answered today.
Your question is not get answered. We will follow back up with you through email. Just going to pause here for a few minutes while I go through some questions already submitted. Thanks again. Alright, so let’s start going through some of these questions. Now. The first question is will hop be certified by 2019 by the office of the national coordinator for health information technology to submit nips info.
So this certification is the it’s the onc certification and it’s how you can submit data to CMS directly. It’s called the EHR submission and it we have opted not to go that path. I don’t even think it’s actually an option for pts. And OTS. I think registry was the only option for them. You would go through this certification.
If you were getting involved in promoting interoperability category the meaningful use one. As we are not part of that category. We are not being certified. We do not need to it shouldn’t it wouldn’t impact you guys in any way know that if we ever do need to we will definitely be pursuing that route, but for the 2018 years, there’s no reason for us to get certified.
Okay, the next question is well how to provide real-time feedback on Clinic performance throughout the reporting year. So if you are a registry customer, yes, we will try it in court early feedback to you based off of your submission if we notice any abnormalities throughout the year. We do our best to catch those outside of the quarterly reports, but we will be also mainly doing it through the quarterly reports for claims-based submissions.
We are looking to possibly do something similar to those pqrs reports that we had in the past. I would caution on those that those are not official with regards to the registry. We actually control what is being submitted. With regards to the claim based submissions. We are guessing based off the data that’s available in TheraOffice.
So the quarterly reports are definitely more trustworthy with regards to that data. It’s kind of the downside the claims we can make our best estimates, but we can’t know for sure on registry we can know for sure because we’re not actually submitting until 2024 those. Next question is will he be able to provide Anonymous data comparing clinics that report through huh?
It’s possibility will be to look into the availability of that will have the data for the Registries will have access to them. I don’t know if we’re allowed to or not. But depending on what we find through that it’s possibility. Next question is our Hospital based providers exempt. Yes. But it’s entirely based off of whether or not you’re submitting institutional claims.
So when you submit a professional claim on a 1500 form or through Nancy professional claim to Medicare, they can know that your NPI is associated with that service and then by doing so they can determine your level of involvement. So with professional claims don’t know with institutional claims, you’re not linking to an individual provider and they can’t know what I would do is on there’s a website called qpp that cms.gov.
You can either just Google Google qpp or look at that exact address and you can actually look up your individual NPI number and that will tell you whether or not they’re considering you to be exempt from the program or not. So I would highly recommend that you’ll see it from previous years. You’ll have to add use a little context to determine what they’re specifically considering us.
Okay. So next question is with the 200 patient count. What do you mean if they see more than one provider you’re saying each patient can count as more than one if they see more than one provider. We have a PT and a PTT a if the same patient see both patients during their plan of care. Does that count as two visits or one visit per each time seemed so they’re not counting visits they’re counting patients and they’re counting patients based off of the claims data that they have the determination periods use.
Nothing, but claims data to determine whether or not you were involved. So if you’ve got a provider and that providers NPI is attached to a patient on any visit throughout the entire year. They are considered to be a one distinct patient for that that provider. So what that means is let’s say you’ve got a patient that’s coming in for treatment and throughout their treatment.
They see 10 different providers. All right, that’s a lot but say throughout the years or just chipping between providers those 10 providers are all all have that patient count as one towards their count for the determination period if that patient comes in and sees one providers rather entire treatment that patient is only counting towards one.
So it does kind of matter depending on how you kind of set up your schedules. Okay, this is another this is a very important question. If you participate optionally not required. Can you be penalized the answer to this question is? Yes, so if you choose to participate in this program and you do not do well at it.
Yes, you can then be penalized. So you want to make sure you either want to be in or you want to be out. You don’t want to do it half way or you don’t want to do it partially. Next question is can we easily use the TheraOffice system to run reports to see where we land on the three inclusion criteria 200 units 200 patients or 90,000 allowable payments.
Yes. There are some reports that you can use for that the distinct patients one. I don’t think we have any standard reports for that. What we’re going to be doing as part of the part of the mit’s wizard setup is there’s a screen that is going to essentially spit out a report that shows you all that data for all your providers.
So we’re building that into the next update is going to be able to be available for everybody to help make that decision. Okay, the next question is how many clinics providers has hot submitted myths for since 2017 and how many have been successful? The answer is none to my knowledge is because pts and OTS have not been involved in the program in the last two years.
So they’re there I think there were a few people who optionally chose to. But they chose to submit through claims based 2019 will be the first year that we are as registry. You have to go through a self nomination process to become that registry and we’ve already completed that process of already received approval for it.
So we anticipate that things will go smoothly. We have set up the software itself through this next update to really ensure a hundred percent reporting and. To also allow you to lock down the system for performance as well. So we’re pretty confident that this is going to go well for for our users in the 2018 reporting year.
Okay. So here’s another question. It’s a good one. It’s a bit of a complex one. So if I hire a PT in 2020 that did nips reporting in 2019 somewhere else. Does that PT or does that come with the PT when working in my clinic and the answer that question is? Yes. So the a person’s mips core will follow them to wherever it is that they’re working next.
So come hiring decisions. It’s going to have an impact in that area there mips core from the previous year’s will impact on that if it’s a new grad, Hiring a new grad. Obviously, they have no previous myth score. It’s a neutral payment adjustment. But this also means for every individual providers.
They really want to be participating in this program to potentially get that that extra incentive.
Next question is how much will hot registry cost or will be an inclusive and current cost? There will be an additional cost to it. The reason for that additional cost is additional work that we’re going to be doing on our side to ensure success successful reporting for you and your providers. So there is an additional cost on that.
It’s very competitive. To other registries out there. We are just now finalizing some some last pieces of information. I know it seems like a lot of this stuff is kind of last minute and late and stuff like that. But unfortunately with how these rules get passed down from Medicare, the final rule just came literally on November 1st.
So we learned some new things in that final rule that that changed so, you know, there’s just some small details that we needed to work out. But as soon as that information becomes available, we’ll make sure to to let you guys know. Next question. Will there be an administrative option to disable mips changes for facilities that are unable to submit it?
Yes. So when you get that next update it’s going to force everybody into going through a mips wizard. In administrator only admin user can do it. But in that wizard you’re going to be choosing whether or not you’re participating in the program if you choose not to participate and you’re not going to see any real differences in the software.
You’re going to notice maybe some new sections, but you’re not going to have to be required to do any of them and nothing’s really going to change in your workflow in any way. Okay, the next question is does mips apply to Medicare replacement plans. I assume that this is for claims based and if it is claims-based, I apologize would need to double-check on this a little bit more will try to get some more information for us for the next webinar.
If it’s registry-based, then you’re submitting for all insurances regardless what it is, but if you’re claiming spaced I want to say no, but let me double-check on this on my side and will confirm with you in one of the upcoming webinars as well. Next question is photo going to be required to use the therapist registry know when you are going to submit your different measures photo will act as one of those within the special tea set.
Was functional status change measures and so it’s definitely going to be a positive thing for anybody. That’s many Maps data by doing photo means you’re doing risk-adjusted outcomes, which is a great thing for this program, but it is not required to participate in these TheraOffice registry. You can still be there still past to submitting data even including those functional status changes without signing up for photo.
Next question is how will ptas be involved with us? It’s the same rules for ptas the same determination period thresholds are going to be used for them just like they are for PT’s. Next question if we have a new enrolling in Medicare in 2019. Are they exempt for only 2019? Yes. That is correct. So only new enrollees within that reporting year will be exempt.
Next question if we send claims on you Bill for or we exempt. Yes for now. Like I said, I would still be aware of the situation because once they kind of figure out how to get data on facilities where they’re not submitting by provider then probably figure out a way to enroll you guys into this program.
Next question is how is the small practice determined? Is it by tax ID or is it by group Medicare number? We Are One tax ID several Medicare IDs It Is by tax ID everything for small practice determinations and just for the determination periods of the whole everything is based off of tax ID.
Welfare office have a wizard for those submitting by a claims and the registry or only those submitting by the registry the wizard will walk you through those kind of questions that we asked before which will include claim submission. So you go in you didn’t the Kate. Yes, I’m participating and then you would also say yes, I am a small practice.
Now the one thing I would warn about on this is that you tell us that you’re a small practice or you will be considered a small practice and choose to submit by a claims throughout the year and then it turns out through Medicare determination periods that you had more npi’s associated with your tax ID, then then then 15 then they will not consider you to be a small practice and I think that that will render your claims data.
In ballot, so you really want to be careful. If you’re right on that, press hold your sitting at around 14 providers. I would I would be careful about going down the claims pass.
Next question if you choose to submit mips via claims, will you not be able to participate in some of the measures or all the measures available through claims? You will not be able to participate in the functional status change measures the outcome measures. There are questions right now about how.
How CMS is going to score claims-based submissions without access to outcome measures, we don’t know the answer to that with certainty whether or not they will say that you just missed out on the the outcomes based ones or say you missed out on them because you were claims submission and then re wait everything based off of.
The only the available measures to you. We unfortunately do not know the answer to that. I’m in contact with some some people from a PTA and CMS to try to clarify on that. Unfortunately, that’s still an unknown. Alright, next question is our private pay patient’s exempt from reporting in the registry.
Nope. It is every Insurance even private pay every patient that you see everyone that is in your system and includes everything even you know, workers comp or Auto patients. It’s all of them.
Did you say something about creating reports for us to build to run out of TheraOffice? We’re going to be trying to do this through the TheraOffice the the Wizard as you’re updating to give everybody access to that information. So we’re not looking to do is report. We’re looking to do it directly through that wizard.
Okay. Next question is we have six therapist to qualify. Each of the therapist must have 200 unique Medicare patients to qualify in the mips. Only one therapist sees greater than 200 Medicare patients and others do not do we still qualify? So what that would mean is that that one therapist that’s over 200 Medicare patients.
They become let’s assume they meet all three of those thresholds. That one therapist becomes required and should you not participate in mips? They will get hit with a penalty the other five if they’re all under it. It becomes an optional submission for them. And then when you come to decide whether or not you want to participate in the program, you can choose to participate individually, which means that one therapist or each of your therapist graded individually each get their own separate score or you can roll them all up together and submit as group.
Next question is when are the measures reported? Is it initially the only it is initially Val for most of them and then re-evaluate on some of them and the functional status measures are at discharge. So it’s a little bit different. We’ll say for any of you that went through that PRS experience where current medications was at one point.
Every visit that is no longer the case. This is mostly just eval jewelry valves. Next question will be able to attest to Improvement activities by a therapist registry at the group level meaning by designated group manager only. Yes part of the therapist registry will also be two attesting to your improvement activities.
If you do not use the therapist registry and you’re going claims-based submission. And you’re still wanting to do the Improvement activities you have to do it through direct submission to I think CMS is Portal but yes through our registry you’ll be able to attest to those improving activities. Is there a reason why all patients need to report the quality measures is this a system issue with TheraOffice or do all Registries have to do that?
Unfortunately, it is not a system issue with TheraOffice. It is for all Registries that it’s just so basically the way that it works is if you’re doing claim submission Medicare can only get data. Claims that is that you’re submitting directly to them. But if you’re going to be doing a registry, then you’re reporting on data in like one some of data submission in the following year so they can get access then to all patients or all pairs.
It wouldn’t matter because you’re submitting outside of claims, theoretically to them. That means that you could submit on all pairs, which means that. They made that requirement. So it is it is a full-blown requirement anyone submitting mips data through registry needs to submit on all pairs regardless of the registry regardless of the pair.
Okay. Now another question, can you report on both claims and registry? Yes. Yes. That is a good question. We recommend kind of sticking to one but if you did happen to some it on both Medicare would take the best of the two, I would focus on one if you are submitting through the therapist registry.
You definitely wouldn’t need to submit on claims. It would just be since it’s the same the same source of data. It wouldn’t be necessary. Can you repeat the website to check for Hospital exemption its qpp got cms.gov. Okay, let’s clean. The next thing is I will G Codes still be on the claims if we use the registry the answer is no so if you threw that wizard choose to submit through the registry, then we will be storing the results of your midst data in a separate table within the TheraOffice database and we will not be including them on the claims.
So the only reason that the G Codes for mips go on the claims is if you’re doing claim submission.
Okay, next question. If we’re on the server base model with TheraOffice. Can we still participate in the registry the answer to this Ranch for this is yes, there might be some additional steps that you need to do. We’re still working through some of those details. It’s one of the last details but need to work out before we kind of do the final registry release.
An information but yes, our plan is to have an option for on-site users to be able to submit mips data as well. Although there might be some some manual uploads that you have to do to us. I’ve gotten a few questions with regards to the fees with regard to the registry. And you said there’d be very comparative to other other registry options out there and we’ll have that information for you guys as soon as soon as we finalize it on our side.
It’s going to be part of the email contact that we send out to you guys.
You mentioned there’s a fee for registry reporting is that paid to CMS or Hands-On Tech that is paid to us. Every registry charges. The reason they charges because of additional work that we’re having to do on our side to be able to do it. So, you know, we’ve got a separate process for setting this all up for you guys for data submission.
We have to we have to attend monthly support calls from CMS to do this. There’s a lot of steps involved. To do that data submission. That’s where the additional fee is coming from.
All right. So I’ll this next question is it’s a little bit detailed and we’re going to be going over it more in the next one, but I’ll try to handle it a little bit now Andrew. Can you clarify how a clinics overall percentage score is calculated give example. So basically what they’re going to be doing is.
You will get a score for each of the categories that are participating in which is quality and Improvement activities. That score is going to be based off of your performance mint which is how well you do within each of those measures for your entire patient base. That score is then going to be for the quality category.
It’s at a certain percentage that gets re waited for pts and OTS because they’re out of the other two categories. And that’s going to be added to the Improvement activity score which will give you a score out of a hundred on essentially how well you performed the calculation for it is pretty complicated.
So I don’t have it off hand will be going over to that in the next one scoring is part of the mips measurement or mips measures and scoring summary is the next webinar, which will go into more detail on that, but it’s based off of how well you’re actually meeting each of those measures that you’re submitting on.
If we choose to report via a different registry will if TheraOffice be able to bypass this section of the documentation. Yeah, if you were doing everything outside of TheraOffice and you don’t need us to do anything with regards to your registry and I would during that wizard process and set up I would choose that to not participate essentially be opting out of it entirely.
So you’re kind of lying to it a little bit. If in optional group and if I don’t participate, well, I get penalized. No just make sure that you are actually in that optional group because you happen to be in the required group 7% can be a big deal.
So we’ve gotten a few questions on that cms.gov site. What we’ll do is part of the follow-up email that down will send out for everybody will be a link to the actual participation lookup page the specific page within that qpp site that you can use to look up your individual and pi and see your level of involvement and.
This is for the previous reporting year and I do not know when CMS going to update their site for 2018. I imagine it’s going to be a little slower. So but you can use the previous year where I would say that this would be helpful is in the type of your clinic not in the determination period amounts because I don’t even know if they ran them for Petey’s from previous years because we were in the program at all before.
Next question is it’s we have 50 Petey’s but only want to have ten reports. Can we do claims reporting? The answer to that question is no Medicare will see that you have 50 providers attached to your tax identification number during that determination period and will determine that the you are not considered a small business small practice and claims-based submission does not become an option for you.
Our Commercial Insurance is requiring the Miss participation or just Medicare CMS Commercial Insurance is are not doing anything with regards to mips as right now. I think there are plans for that to be the case. And that being said if you are submitting registry to Medicare that still does require that you complete the quality measures on all your patients not just your Medicare patients.
So we’ve got some additional questions on ptas and ptas. It’s a rough subjected kind of depends on which state you’re located in which kind of facility you have setup. You’ve got ptas who never appear on claims, then they’re not. Part of the program because Medicare will see them and the determination period will have them just be completely ineligible.
If you have ptas that never do evals never do anything like that never submit any of that data, then they would be considered an eligible providers. If you’ve got a lot of ptas but the pts are doing evals and every other way, then you would want probably to submit as a group so that the payment adjustment can be applied to any of the daily notes that the ptas are treating for.
Do you know when listing medications do they have to be entered into TheraOffice or we can we just say scan list. The scan list does work and part of the current medications update that we’re doing allows you to a test of a scanned image note being placed in the medical record. Next question is Reveille evals are not paid by Medicare or to report a functional status with a re valve CPT code that has to do just with the.
Like qualifications of each measure and whether or not the readout codes are part of those measures whether or not they trigger that measure so if you’re not reporting a real code, then you do not need to submit on that measure at that time, but we’ll go into more detail on this in the next webinar.
Next question is if we choose to submit by a Claims. Can we change later to registry for the therapist registry sign up will end at the end of the year. So if you are going to be submitting out of that method you can change it until the end of the year. That’s when we need to you. Just sign up for bye.
The next question is how do we report mips on a patient who gets discharged for non-compliance. It just stopped coming to therapy is going to be ready to relate to those functional status ones. And yes, it’s problem. I don’t know if they have a perfect solution for it yet. Most likely in those instances.
You just wouldn’t report for them. It wouldn’t count against you because you don’t have the discharge code that keeps them as part of the denominator.
Just to clarify a cash or self-pay patients included in the reporting for the registry. Yes. I know that sounds crazy. But yes, it is part of your entire patient based doesn’t matter whether or not they have an insurance. Did you say that Apple R is going to be phased out at the end of the year?
Yes folks over limitation reporting is gone. As of January 1st for Medicare insurance has if you have a local commercial insurance that adopted the program, I would contact them directly to find out whether or not they’re continuing with functional reporting as of January first. We’ll see you in as tell us if we are required to participate or do we have to decide ourselves I have heard I have heard that the actual communication by CMS as to whether or not you are considered to be a required provider like come much later in the year.
Then you would want it to be so yeah, it’s not. That’s not a great answer. I wish I could give you a better answer on that. They have a kind of timing timeline issue with how these final rules get rolled out and how they’re able to process information enough. I think they’re kind of just assuming that everybody gets involved in this or the least.
That’s what they’re hoping for. So I think the answer to your question is yes, they’ll tell you it’ll probably be too late. I would do your best to determine your level involvement before that. If we have 50 Petey’s but only want to 10 to test the waters would we do individual registry or group registry reporting?
You would do individual registry?
If submitting through registry to CMS only apply Medicare patients to whether you meet exceed or get penalized and are not given non-medicare patients. So if this is related to the determination periods, and whether or not your level of enrollment is required or not that is based off of only Medicare patients because it’s the only claims data that Medicare has access to.
What about per diem providers that work out of several unrelated clinics. So when they go to make the determination periods, it will be based off of their NPI tax identification number combinations. So if you’ve got a provider is attached to multiple pins, then that provider will only. That providers level of deter level of involvement within those determination periods will be made on each separate tin and they’ll need to meet those thresholds on each one.
So in those instances most likely those providers are not going to be required. They might not even be eligible at all. If there are thresholds are not well. How will the progress note be impacted? No, impact on progress notes. This is entirely based off of CPT codes. That’s how each quality measure is determined as to whether or not you need to do that measure for that that day of service.
It’s based off of CPT code not partnership. Purdue claims-based we still use TheraOffice together data. Yep, all the updates that are coming in. The next update for mips will be applying to claims based submissions will be gathering that data within TheraOffice same as we do for claim or registry will just be adding it as CPT codes on your claims.
Okay. Next question. What is the highest percent increase possible if a clinic decided to submit information only by a claims meaning we wouldn’t be participating the outcomes portion. Unfortunately, there’s no way to answer this question without knowing what everybody else does in the industry or not in the industry and all of healthcare.
So. I would say that if you’re only doing claims and they decide to not re wait that based off of the lack of an outcomes measure for claims based submission and your deducted for that amount. Then you’re probably going to fall just short of that exceptional performance bonus and. which. Ideally, if you do everything else you’re probably going to be somewhere around 1% or so would be probably my estimate of a maximum, but that I wouldn’t quote me on that.
It really depends on what happens. We won’t know that for sure for two years actually a little more than that about two and a half years. Our scores is Petey’s compared to only PT’s or to all providers all providers. It’s not discipline specific.
Okay, so we have gotten a lot of questions. I would gone through a decent amount of them. Hopefully we got through most of them. Thank you. Everyone again for attending today’s webinar. I believe we’ve run out of time. So don’t want to keep everybody here too late. If we do not answer your question.
What we’ll do is we’ll do an additional follow-up will do the. The first one to everybody including the PowerPoint and the link to that QP site and then the second follow-up will do is an FAQ based off of some unanswered questions from this webinar swing just covering for everybody. So again, thank you everyone for attending today’s webinar and we hope this was really helpful for you and I still got a bunch more questions.
So make sure to sign up for those later webinars. Hopefully we can kind of complete this whole process for everybody and if you signed up for more registry information, We make sure get a contact out to you soon about that as well. So, thank you again everyone for attending today’s webinar and have a great day.
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Tue, Sep 17, 2019 | 1:00 PM - 2:00 PM CST