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Gawenda Seminars

Seminars and Consulting

Upcoming Seminars

Understanding the Complex World of Therapy Services:
Documentation, Coding and Billing for Physical & Occupational Therapy

Join us at venues in TX and LA from Jan 22nd – Feb 28th. More Details

Group

MIPS 2019: Must I Report as a Group

by 1 Comment

Effective January 1, 2019, physical therapists, occupational therapists and speech-language pathologists in private practice (submit claims on a 1500 claim form) are able to participate in the Merit-Based Incentive Payment System (MIPS) for Performance Year 2019. If an individual therapist exceeds all 3 of the low-volume thresholds during both determination periods, they will be required to participate in MIPS in 2019. But what if as an individual, not one therapist in a practice exceeds all 3 of the low-volume thresholds during both determination periods, but the group does. Must the group then participate in MIPS in 2019?

The answer is

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MIPS Questions and Answers: Part 4

by 9 Comments

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?
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I hope you enjoyed Part 4 of MIPS FAQ’s. Thank you for being a Gold Member!