4 Things You Need to Know About MIPS


Whether you love it, hate it, or still don’t completely understand it, the Merit-based Incentive Payment System (MIPS) is now a fact of clinical life for some.

By Michelle Vanderhoff, MA, MBA

While most private practice owners are not required to participate, many are eligible to and should consider doing so, especially if they are already focused on quality improvement.

Here are answers to some common questions.

Am I eligible?

If you treat Medicare Part B patients within a private practice, you might be eligible.

Solo outpatient private practice providers are required to participate in MIPS if over the course of a year they have more than $90,000 in allowable Medicare Part B charges, treat more than 200 Part B patients, and provide over 200 Part B services. These criteria make up what the Centers for Medicare and Medicaid Services (CMS) calls the “low-volume threshold.”

Group practices (defined as 2 or more providers practicing under a single taxpayer identification number) that meet the low-volume threshold are eligible (but not required) to participate in 2019 for the potential payment adjustment.

Solo practitioners or group practices that meet only one or two of the low-volume threshold criteria will be eligible to “opt in”—that is, they annually can choose to report to MIPS for the potential payment adjustment. (Once opted in, they would be committed to participating for the year.) Practices that do not meet any of the low-volume threshold criteria can report voluntarily, without any payment adjustment.

What would I need to report?

The two required categories for reporting in 2019 for physical therapists are Improvement Activities and Quality. Scores are based on points, not pass/fail.

Improvement activities show that clinicians are engaging in quality-improvement efforts in clinical practice, and they must be performed for 90 days or more during the performance year. Some examples include employing patient-reported outcome tools, regular training in care coordination, and using a qualified clinical data registry—such as the American Physical Therapy Association’s (APTA) Physical Therapy Outcomes Registry—to assess treatment outcomes and improve patient safety. APTA has compiled a list, from the complete list of eligible activities, of those most appropriate for physical therapists.

Quality scores will be calculated using the top six quality measure results out of all the measures a practice reports. Practices also can earn bonus points for reporting more than the one required “high-priority” quality measure.

Some practice owners might be apprehensive about payment decisions being based on outcomes-based quality measures. James Irrgang, PT, Ph.D., is chair of the Physical Therapy Outcomes Registry’s Scientific Advisory Panel. He recently told PT in Motion magazine, “The measures have to be meaningful to patients and clinicians and truly reflect the quality of the outcome for the treatment provided.” Irrgang also plugged participation in the Registry, which is the only physical therapy registry that has been submitting MIPS data since 2017: “We’re collecting information on patients that could be used to explain a clinician’s results or adjust the risk based on the results.”

How are data reported, and how would I know my score?

Solo practices or those with 15 or fewer eligible clinicians can report via claims, but they would not find out their scores until the end of the year. Larger practices must report via third-party vendor.

Using a vendor allows practices to get feedback throughout the year to help improve their scores. For this reason, APTA recommends that practices of all sizes use a vendor for reporting.

CMS identifies vendors as electronic health records, qualified registries, and qualified clinical data registries (QCDRs). Both qualified registries and QCDRs collect and report quality data for clinicians. However, the APTA Physical Therapy Outcomes Registry, a QCDR, contains more process measures and more outcome measures than a qualified registry, allowing the practice to report more measures from which CSM will take the top six results for scoring in the Quality category. Also, using a QCDR automatically fulfills several items in the Improvement Activities category.

Why should I participate if I’m not required to?

Participating in MIPS allows physical therapists and practices that meet the eligibility requirements to earn incentive payments. Practices that scored well in the Quality category under a physician quality reporting system (PQRS) would potentially score well in the MIPS Quality category. Because MIPS may be expanded in the future to include more practices, participating now will help your practice prepare.

Collecting this outcomes data can help you understand your practice and the patients you serve—information you will need when deciding if and when to participate in an alternative payment model (APM) and which model might work best for your setting.

And if you report using a QCDR, you can use real-time analytics throughout the year to see how well your practice is meeting performance goals, giving you the clinical intelligence you need to take control of payment.

APTA has a number of resources to help you understand MIPS and the Quality Payment Program, including fact sheets, webinars, and a decision tree for determining eligibility:



Michelle Vanderhoff

Michelle Vanderhoff, MA, MBA, is lead editor at the American Physical Therapy Association in Alexandria, Virginia. Questions about this article may be directed to advocacy@apta.org.

Copyright © 2018, Private Practice Section of the American Physical Therapy Association. All Rights Reserved.

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