Common Questions from our August 2018 MIPS Webinar

We get it, MIPS is a tough program to get a handle on. It’s CMS’ favorite on-again off-again relationship and we, PTs, often get caught in the middle.

Luckily, Clinicient is here to help you navigate the relationship between CMS, MIPS and PTs and how you can best prepare to participate in MIPS in 2019. Read below for a collection of answers to the most common questions we received during a recent MIPS focused webinar featuring Medicare Compliance Expert, Nancy Beckley, and Clinicient co-founder, Jerry Henderson. Missed the webinar? Watch the recording here.

    1. What is the goal of MIPS?

      Overall, the goal of any quality reporting program is to encourage physician performance that improves care and benefits patients. Specifically, CMS wants to increase the focus on quality and value-based care. MIPS is one of the programs designed to help achieve this.

    2. How will MIPS work for PTs, OTs and SLPs?

      CMS recently proposed that beginning in 2019, PTs and OTs will be included as eligible professionals to participate in MIPS (at the time of this writing, SLPs were still not included as eligible professionals). In order to be eligible to participate, physicians must meet at least one out of three requirements – number of services provided, number of patients and allowed charges. If you meet all three of these thresholds, you are required to participate. If you meet at least one out of three of the requirements you can opt-in to participate.Therapists earn a payment adjustment based on evidence-based and practice-specific quality data. Therapists show they provided high quality, efficient care supported by technology by sending in information in the following categories; Quality Measures, Improvement Activities, Cost, and Promoting Interoperability. For 2019, CMS has proposed that therapists will only be assessed on Quality Measures and Improvement Activities.
      MIPS is comprised of these four Performance Categories that make up a composite performance score (CPS) of a possible 100 points. Therapists can submit their individual score or a score for their entire group.

    3. How will MIPS affect hospital-based outpatient PT departments?

      Only practices that bill under the professional fee schedule as Part B providers are eligible to participate in MIPS. Practices that bill as facilities (rehab agencies, hospital outpatient departments and CORFs) are not eligible or subject to the performance bonuses or penalties.

    4. Is there a potential for Medicare to push MIPS participation out past 2019?

      The long-term goal of CMS is to move totally away from fee for service to alternative payment models. MIPS is a hybrid program; i.e. fee for service with quality incentives and an interim step in that transition.

    5. Can you explain how MIPS will work for a group? Is it better to submit as a group or individually?

      If you are in a group practice submitting claims under Part B, you will be able to elect whether to submit under your group NPI or individual NPIs.At this writing, we believe that the entire group must elect one submission method or another. In other words, you will not be able to submit some members of your group under individual NPIs and others under the group NPI. Submitting as a group is generally easier to administer.

    6. Does the number of patients mean strictly the amount of Medicare patients in a year or number of treatment visits?

      The minimum patient count refers to distinct Medicare beneficiaries only.

    7. Is the FLR tentatively scheduled to end in 2018 or end of 2019? Have seen both mentioned in other documents.

      FLR is proposed to end for everyone on December 31, 2018.

    8. Was the therapy cap officially eliminated?

      Technically, the therapy cap was eliminated effective January 2018. But, practically speaking, there is very little difference from the therapist’s perspective between the therapy cap with automatic exceptions that was effective in 2017 and prior years. The KX modifier still has to be applied at an arbitrary level designated by CMS. The KX indicates that the therapist is stipulating that continued care meets Medicare standards for reasonable and necessary treatment. For 2018, the level at which the KX needs to be applied is $2010 in allowed charges for PT/SLP combined or, separately for OT services. In addition, Medicare contractors are more likely to review your records to assure medical necessity at $3,000 in allowed charges for PT/SLP combined or, separately for OT services.

    9. How will clinics without an EMR handle this change? I see MIPS being extremely difficult or nearly impossible to implement without an EMR. Would that be a fair assessment?

      Yes, we believe that is a fair assessment. It is very difficult to know what measures are applicable at what visit without a system that automatically queues you. Clinicient does exactly this and much more. Learn more here.

    10. Is there a way I can view how many Medicare services I’ve performed in past years?

      Yes! The ProPublica website has published a “Treatment Tracker” (access it here) that profiles the volume of services for all Medicare providers. Note that this data is from 2015 but it will give you a rough idea whether or not you will be required or eligible to participate in 2019.

    11. How will Keet help with claims-based reporting?

      Keet helps by administering patient-reported outcomes questionnaires to your patients and scoring the surveys automatically. That data can then be submitted to a registry or QCDR.


The information provided herein is intended to be general in nature. It is not offered as legal or insurance related advice, and is not a complete description, or meant, or intended, to replace or be interpreted as specific, of Medicare requirements. Although every effort has been made to ensure the content herein is correct, we assume no responsibility for its accuracy. Contact Department of Health & Human Services (DHHS) Centers for Medicare and Medicaid Services (CMS) for more information.

2 thoughts on “Common Questions from our August 2018 MIPS Webinar

  1. #8 mistakenly groups PT/OT together with SLP services separate. PT and SLP are the 2 services grouped for determining the amount of charges billed prior to requiring the -KX modifier..

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