Is the MIPS payment adjustment applied before or after sequestration? Is the MIPS payment adjustment applied to the Medicare paid amount or Medicare allowed amount for each CPT code? When considering a small practice, are PTAs, OTA’s, part-time or PRN employees considered in the number of clinicians greater or less than 15? If a physical therapist (PT), occupational therapist (OT) and/or speech-language pathologist (SLP) participates in MIPS in Performance Year 2021 and scores below the minimal Performance Threshold Score and now will receive a negative payment adjustment in 2023, they leave this practice and begin work at another private practice, does this negative payment adjustment follow them to their new practice? If a therapist works in 2 or more different private practices and all 3 low-volume thresholds are exceeded when adding the 3 low-volume thresholds from all of the clinics together against the therapist’s NPI, would they be required to participate in MIPS at all of their private practices? Please clarify group under one TIN. Lets say we have 10 NPIs (all physical therapists) who all reassign their payments to one TIN and the total of these 10 exceed all three threshold’s. Does this then make it mandatory to participate in MIPS in Performance Year 2021? We are considered a group as we all bill under the same TIN. However, each individual NPI (clinician) does not exceed all 3 of the low-volume threshold’s during both determination periods. Are we required to participate as a group? In Performance Period 2021, how are quality measures scored? How is the 70% data completeness calculated? In Performance Year 2021, how many quality measures must physical therapists, occupational therapists and speech-language pathologists report? What is the definition of a small practice? For MIPS reporting in Performance Period 2021, how is a virtual group defined? For MIPS reporting in Performance Year 2021, how is a group defined? For MIPS reporting in Performance Year 2021, how is an individual defined? How can I participate in the MIPS program in 2021? What is the minimum score I need to achieve in 2021 to avoid a negative payment adjustment in 2023? What are the payment adjustments if I report successfully or unsuccessfully in the 2021 MIPS program? What if I do not exceed all 3 of the low-volume thresholds, can I opt-in to the MIPS program in 2021? How is the > 200 covered professional services determined under the Medicare Physician Fee Schedule? How is the > 200 unique Medicare beneficiaries calculated? How is the $90,000 in Medicare Part B allowed charges calculated? For Performance Year 2021, is there a way for me to check right now if I did exceed all 3 of the low-volume thresholds during the first determination period? Is the low-volume threshold based on traditional Medicare Part B claims only or ALL claims? What are the 3 low-volume thresholds, that if exceeded during both determination periods, would require the MIPS eligible clinician participate in MIPS in Performance Period 2021? What is the determination period that CMS will use to see if an eligible clinician will be required to participate in MIPS in 2021? Does MIPS apply to rehabilitation agencies? Is there an easy way to know if I am a private practice with the Medicare program? What practice setting(s) does MIPS apply to in calendar year 2021? How will 2021 MIPS payment adjustments be reflected on remittance advice (RA) documents? Is the MIPS payment adjustment applied to the Medicare paid amount or Medicare allowed amount for each CPT code? s the MIPS payment adjustment applied before or after sequestration? What if a therapist who received multiple MIPS scores in Performance Year 2019 resulting in different payment adjustments for the practices they are working at that will affect the 2021 Payment Period now begins practicing at a new private practice in calendar year 2021, which payment adjustment follows them to this new NPI/TIN combination? Is it possible for a therapist who has their own individual NPI number and is employed or contracted by multiple private practices (different TINs) to have different scores and subsequently, different payment adjustments for each practice they are employed at? In 2020, how are quality measures scored? What are the payment adjustments if I report successfully or unsuccessfully in the 2020 MIPS program? What is the determination period that CMS will use to see if an eligible clinician will be required to participate in MIPS in 2020? How does CMS calculates the penalty for those choosing not to participate/report? Regarding the Improvement Activities, how can we determine which Improvement Activities are considered high-weighted and which are considered medium-weighted? How do we go about opting in and when is the deadline? If we have 11 therapists and 7 physicians but all therapy billing is incident to the physician, are we classified as a small practice since we only have 7 physicians? If we are excluded from MIPS, do not want to opt-in to MIPS and we submit via claims, is there anything special we need to do? If we are a small group private practice who is NOT required to participate, but eligible, will we be penalized if we do not participate? Are the measures to be reported for the Initial Evaluation only or do you have to report them on every visit? Are the quality categories only completed at the initial visit? Our EHR says that due to MIPS every one of our patients must do a functional outcome test every 30 days. They will be reporting through a registry for us. Is this correct or just a rule they are putting in place on their own? As a small practice, if we don’t meet the criteria to be apart of MIPS, would we no longer get a Medicare payment increase? How often to you have to attest for Improvement Activities? Please clarify how to report Improvement Activities and how often to report? When determining the > $90,000 in Medicare allowed charges, is this the amount we bill Medicare or is it the amount that Medicare actually paid us? When considering a small practice, are PTAs, OTA’s, part-time or PRN employees considered in the number of clinicians greater or less than 15? We have a small practice with 4 physical therapists who have all reassigned their benefits to the group TIN. Individually, each therapist does not exceed all 3 low-volume thresholds requiring them to participate in MIPS in 2019. However, their combined group data does meet the criteria. So do we have to opt in as a group? As a CORF, we bill using UB-04 claim form, can we opt-in? Please clarify group under one TIN. Lets say we have 10 NPIs who all reassign their payments to one TIN and the total of these 10 exceed all three threshold’s. Does this then make it mandatory to participate in MIPS? We are considered a group as we all bill under the same TIN. However, each individual NPI (clinician) does not exceed all 3 of the low-volume threshold’s. Are we required to participate as a group? If a therapist works 2 or private practices, and all 3 low-volume thresholds would be exceeded when tracking against the therapist’s NPI, would they have to participate in MIPS at all of their private practices? If we are mandated to participate in MIPS in 2019, do we start January 1, 2019? If we are going to opt out, is there a process you need to go through ? Do you need to opt out on the CMS website? When is the deadline to make a decision to opt in? Can a Group report measures via claims? If a group opts in and successfully or unsuccessfully participates in MIPS in 2019, does the positive or negative payment adjustment follow an individual if they switch to a different private practice in 2021? In 2019, what outcome measures are available to physical and occupational therapists? In 2019, what high priority measures are available to physical and occupational therapists? In 2019, how can you submit quality measures to the Centers for Medicare and Medicaid Services? In 2019, how are quality measures scored? What is a topped out measure? What is the minimum score I need to achieve in 2019 to avoid a negative payment adjustment in 2021? How can I participate in the MIPS program in 2019? For MIPS reporting in 2019, how is an individual defined? For MIPS reporting in 2019, how is a group defined? For MIPS reporting in 2019, how is a virtual group defined? What are the 4 performance categories in the MIPS program? In 2019, how can physical therapists, occupational therapists and speech-language pathologists report quality measures to CMS? What is the definition of a small practice? In 2019, how many quality measures must physical therapists, occupational therapists and speech-language pathologists report? How is the 60% completeness defined? In calendar year 2019, what professionals will be considered an eligible clinician for MIPS? What is a MIPS eligible clinician? How will I know if I will be required to participate in MIPS in 2019? In 2019, what are the 3 low-volume thresholds? How is the $90,000 in Medicare Part B allowed charges calculated? How is the > 200 unique Medicare beneficiaries calculated? How is the > 200 covered professional services under the Medicare Physician Fee Schedule? What is the determination period that CMS will use to see if an eligible clinician will be required to participate in MIPS in 2019? What if I do not exceed all 3 of the low-volume thresholds, can I opt-in to the MIPS program in 2019? What are the payment adjustments if I report successfully or unsuccessfully in the 2019 MIPS program? What does MIPS stand for? What did MIPS replace? When did MIPS start? What practice settings does MIPS apply to? In calendar years 2017 and 2018, could physical therapists, occupational therapists and speech-language pathologists in private practice participate in MIPS? For calendar year 2019, is the Centers for Medicare and Medicaid Services (CMS) considering adding physical therapists and occupational therapists in private practice as eligible MIPS clinicians? What are the 4 performance categories for the MIPS program?

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