The Physician Quality Reporting System (PQRS) that physical, occupational and speech therapists have had to participate in the past several years to avoid a payment reduction ended on December 31, 2016. PQRS was replaced with a new program called Merit-Based Incentive Payment System (MIPS) that combines 3 previous programs and adds one additional category.
Providers participating in MIPS will have to show they provided high quality, efficient care supported by technology by sending in information in the following categories:
- Quality (Replaces PQRS)
- Improvement Activities (New Category)
- Promoting Interoperability (Replaces the Meaningful Use Program)
- Cost (Replaces the Value-Based Modifier)
In 2017 and 2018, physical therapists (PTs), occupational therapists (OTs) and speech-language pathologists (SLPs) in private practice, either therapist owned or physician owned, were not mandated to participate in MIPS. However, in 2019, this is all changing. The Centers for Medicare and Medicaid Services (CMS) is proposing to add physical therapists and occupational therapists in private practice as eligible professionals who would be required to participate in MIPS unless they meet at least one of the low-volume thresholds.
CMS is also considering adding SLPs as an eligible provider, but that would be dependent upon if there would be enough measures for the speech-language pathologist to report on. This will not be known until the final rule is released on or about November 1, 2018.
So, should PTs and OTs in private practice care about MIPS? The answer is yes, no, maybe so, depends. The answer is yes if they do not meet one of the low-volume thresholds as if they decide not to participate or if they do participate but do not meet a minimum score, they would be subject to a negative payment adjustment in 2021 as high as -7%.
The answer may be no if they meet one of the low-volume thresholds and do not wish to opt-in to the MIPS program to be eligible for the chance for a positive payment adjustment in 2021.
I know this is confusing and this article is not intended to teach you everything about MIPS. Over the next few months, I will write and publish articles on the 2019 MIPS program as it pertains to PTs and OTs in private practice. In addition, I will be conducting a webinar on the 2019 MIPS program on September 26, 2018 from 1:00pm – 2:30pm EST. For additional information on the webinar and to register, click HERE.
All material posted on our website is the intellectual property of Gawenda Seminars & Consulting, Inc. and can’t be used, reproduced, or posted as your own material without the prior written approval of Gawenda Seminars & Consulting, Inc.
This article is not intended to and does not serve as legal advice or as consultative services, but is for general information purposes only.
Will PTs and OTs in Rehab Agencies be required or have the option to participate in MIPS?
No. The Centers for Medicare and Medicaid Services (CMS) is proposing to add physical therapists and occupational therapists in private practice as eligible professionals who would be required to participate in MIPS unless they meet at least one of the low-volume thresholds.
My practice has an NPI for the practice and separate NPI for each PT and OT. Will the low volume threshold apply to the practice as a whole or to each discipline?
Each individual PT or OT.
Can we still opt-out of the MIPS and take the payment deduction for private practice for physical and occupational therapist. ?
I will be discussing who must participate in MIPS to avoid the payment reduction and who will have options in future articles over the next 3-4 months. In addition, I will be doing a webinar on MIPS on September 26, 2018. For additional information, go to http://gawendaseminars.com/2019-mips-webinar/