For calendar year 2022, physical therapists, occupational therapists and speech-language pathologists will once again be considered Merit-Based Incentive Payment System (MIPS) eligible clinicians. In this article, I will answer some of the more frequent questions I receive about the MIPS program. In addition, I did a webinar on December 16, 2021 titled “2021 MIPS for Physical, Occupational and Speech Therapy Services“. For additional information on this webinar and to order the webinar playback link, click HERE.
What practice setting(s) does MIPS apply to?
Is there an easy way to know if I am a private practice with the Medicare program?
Does MIPS apply to Rehabilitation Agencies?
What is the determination period that CMS will use to determine if an eligible clinician will be required to participate in MIPS in 2022?
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 2022?
Is the low-volume threshold based on traditional Medicare Part B claims only or ALL claims?
For Performance Year 2022, 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?
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 determined under the Medicare Physician Fee Schedule?
What if I do not exceed all 3 of the low-volume thresholds, can I opt-in to the MIPS program in 2022?
What are the payment adjustments if I report successfully or unsuccessfully in the 2022 MIPS program?
What is the minimum score I need to achieve in 2022 to avoid a negative payment adjustment in 2024?
How can I participate in the MIPS program in 2022?
For MIPS reporting in Performance Year 2022, how is an individual defined?
For MIPS reporting in Performance Year 2022, how is a group defined?
For MIPS reporting in Performance Period 2022, how is a virtual group defined?
What is the definition of a small practice?
In Performance Period 2022, how many quality measures must physical therapists, occupational therapists and speech-language pathologists report?
How is the 70% data completeness calculated?
In Performance Period 2022, how are quality measures scored?
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?
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 Period 2022?
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?
If a physical therapist (PT), occupational therapist (OT) and/or speech-language pathologist (SLP) participates in MIPS in Performance Year 2022 and scores below the minimal Performance Threshold Score and now will receive a negative payment adjustment in 2024, they leave this practice and begin work at another private practice, does this negative payment adjustment follow them to their new practice?
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?
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