MIPS Questions and Answers: Part 4
Question
How does CMS calculates the penalty for those choosing not to participate/report?
Answer
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Question
Regarding the Improvement Activities, how can we determine which Improvement Activities are considered high-weighted and which are considered medium-weighted?
Answer
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Question
How do we go about opting in and when is the deadline?
Answer
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Question
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?
Answer
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Question
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?
Answer
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Question
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?
Answer
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Question
Are the measures to be reported for the Initial Evaluation only or do you have to report them on every visit?
Answer
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Question
Are the quality categories only completed at the initial visit?
Answer
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Question
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?
Answer
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Question
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?
Answer
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Question
How often to you have to attest for Improvement Activities?
Answer
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Question
Please clarify how to report Improvement Activities and how often to report?
Answer
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Question
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?
Answer
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Question
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?
Answer
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Question
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?
Answer
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Question
As a CORF, we bill using UB-04 claim form, can we opt-in?
Answer
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Question
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?
Answer
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Question
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?
Answer
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Question
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?
Answer
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Question
If we are mandated to participate in MIPS in 2019, do we start January 1, 2019?
Answer
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Question
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?
Answer
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Question
When is the deadline to make a decision to opt in?
Answer
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Question
Can a Group report measures via claims?
Answer
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Question
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?
Answer
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I hope you enjoyed Part 4 of MIPS FAQ’s. Thank you for being a Gold Member!
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We are a small practice of 9 PTs, none of us meet the three criteria. So we are not required to participate, but if we OPT IN and participate and fail to report correctly, will we have a negative payment adjustment in 2021?
Yes!
How is MIPS reported on a 1500 form?
With the applicable G-codes for each measure you are reporting.
Thank you Rick for all of this valuable information.
If we are not required to participate can we voluntarily participate without receiving a negative or positive and just stay $ neutral?
Yes, you can opt-in to voluntarily report and not be subject to any payment adjustment in 2021. You will receive a report and how you would have done if you had opted-in to go for a payment adjustment in 2021.
Have the 2019 MIPS PT measures for claims based been put out there or are we to just bill right now claims bases with the 2018?
The 2019 MIPS Measures have been released and can be accessed at https://qpp.cms.gov/about/resource-library