Hot Topics: Understanding MIPS for Therapists

What is MIPS?

The Merit Based Incentive Payment System (MIPS) was established under Medicare Access and CHIP Reauthorization Act (MACRA) of 2015. MIPS is designed to provide incentives for providers for certain quality measures, improvement activities, and the use of EMRs that meet certain standards. MIPS scoring is based on:

Quality Measures, which are partly developed from the Physician's Quality Reporting System (PQRS).
Improvement Activities which require providers to attest that they have participated in projects to improve care coordination, beneficiary engagement, and patient safety.
Advancing Care Information, which requires the use of EMRs that meet certain standards.

What is the MIPS relationship to the quality payment program?

MIPS is one of two tracks in the Quality Payment Program, which was developed to help improve Medicare by helping care givers focus on care quality making patients healthier. It repeals:

The Sustainable Growth Rate (SGR) Formula
Streamlines multiple quality reporting programs into the Merit-based Incentive Payment System (MIPS)
Provides incentive payments for participation in Advanced Alternative Payment Models (APMs)

Picture of MIPS for PT, OT and SLP tip sheet

Download our MIPS glossary to gain a better understanding of common and not so common MIPS terminology.

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What is the overall goal of MIPS?

CMS wants to increase the focus on quality and value-based care. MIPS is one of the programs designed to help achieve this.

Who is eligible to participate in MIPS?

“MIPS” eligible clinicians like physical therapists, occupational therapists and speech-language pathologists who participate in Medicare Part B.

How does MIPS work?

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.

MIPS is comprised of 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.

Quality

Replaces PQRS.

Improvement Activities

New category.

Advancing Care Information

Replaces the Medicare EHR Incentive Program also known as Meaningful Use.

Cost

Replaces the Value-Based Modifier.

What will determine a therapist’s MIPS Score?

A therapist’s MIPS performance score will factor in performance in 4 weighted performance categories. The scale is based on a 0-100 point scale:

When and what do therapists need to do regarding MIPS?

2017 – 2018

Therapists voluntarily report into MIPS /continue to report PQRS data (quality measures) to practice reporting. In 2017, only private practice PTs that submit claims to Medicare carriers using the 1500 claim form or 837-P can formally participate in MIPS.

2019

Therapists required to report quality data into MIPS. Reporting therapists are eligible for a positive or negative payment adjustment of +/- 7% in 2021.

2021

Therapists eligible to receive first MIPS payment adjustment. Reporting therapists are eligible for a positive or negative payment adjustment. The potential maximum adjustment % will increase each year from 2021 to 2022.

How does the MIPS payment adjustment work?

The payment-adjustment year is two years after the data-collection year as will PQRS. That means that when a therapist reports in 2019, the adjustment will be made to payments in 2021.

Under MIPS therapists with composite scores below the performance threshold will be subject to MIPS penalties on a sliding scale, with maximum penalties of up to 7% in 2021, and 9% in 2022 and beyond.