On July 29, 2019, the Centers for Medicare and Medicaid Services (CMS) released the proposed rule for services paid under the Medicare Physician Fee Schedule and Other Changes to Part B Payment Policies as well as Updates to the Quality Payment Program. The latter would include the Merit-Base Incentive Payment System (MIPS). Remember that only physical therapists (PTs), occupational therapists (OTs) and speech-language pathologists (SLPs) that practice in a private practice (submit claims on a 1500-claim form to the Medicare program) are eligible to participate in MIPS. This would include a therapist owned private practice or a physician owned private practice. PTs, OTs and SLPs in all other practice settings are not eligible to participate in MIPS.
For performance period (PP) 2020, CMS estimates that approximately 818,000 clinicians would be MIPS eligible clinicians. PP 2020 score will impact the MIPS eligible Medicare payment in payment year (PY) 2022. CMS is estimating that MIPS payment adjustments will be approximately equally distributed between negative MIPS payment adjustments ($584 million) and positive MIPS payment adjustments ($584 million) to MIPS eligible clinicians, as required by the statute to ensure budget neutrality.
Beginning with performance period 2021, CMS is proposing to apply a new MIPS Value Pathways (MVP) framework. The MVP framework would connect measures and activities across the 4 MIPS performance categories, incorporate a set of administrative claims-based quality measures that focus on population health, provide data and feedback to clinicians, and enhance information provided to patients. CMS believes the MVPs will reduce the complexity of the MIPS program and the burden to participate. To read about MVPs, click
Proposed Weights by MIPS Performance Category for the 2022 through 2024 MIPS Payment Years
Performance Category 2022 MIPS Payment Year 2023 MIPS Payment Year 2024 MIPS Payment Year
Quality Performance Category
CMS is proposing to weigh the quality performance category at
Cost Performance Category
CMS is proposing to weight the cost performance category at
Improvement Activities Performance Category
CMS is proposing to increase the group or virtual group reporting threshold from at least
Promoting Interoperability Performance Category
For the 2022 MIPS payment year, the performance period for the Promoting Interoperability performance category is a minimum of
Complex Patient Bonus for the 2022 MIPS Payment Year
CMS is proposing to continue
For performance year 2017, the performance threshold was 3 points. For performance year 2018, the performance threshold was 15 points. For performance year 2019, the performance threshold was 30 points. For performance year 2020 which will impact your 2022 payments, CMS is proposing a performance threshold of
QCDRs and Qualified Registries
Beginning with performance year 2021/payment year 2023, Qualified Clinical Data Registries (QCDRs) and Qualified Registries will have to attest that they can provide performance feedback at least
New Measures for Performance Year 2020
CMS is proposing 1 new quality measure that should be applicable to physical therapists. The name of the measure is
PT/OT Specialty Set Quality Measures
CMS is proposing to add the following quality measures to the Physical Therapy/Occupational Therapy Specialty Set:
CMS is proposing to delete the following quality measures from the Physical Therapy/Occupational Therapy Specialty Set:
Speech Language Pathology Set
CMS is proposing to add the following quality measures to the Speech Language Pathology Specialty Set:
CMS is proposing to delete the following quality measure that was applicable to physical and/or occupational therapy
Previously Finalized Quality Measures with Substantive Changes Proposed for the 2022 MIPS Payment Year and Future Years
I hope you found this article to be helpful. When the final rule is released on or after November 1, 2019, watch for another article on MIPS 2020. Thank you for being a Gold Member!
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