MIPS Reporting for Practice Perfect EMR Users
What is MIPS Reporting?
You may have heard about the acronym, MIPS, as being a new requirement for your practice, whether you are a part of a larger group, or just a solo therapist. But what is it, really? And do you need to worry about it? “MIPS” stands for the Merit-based Incentive Payment System and replaces PQRS, Value Based Modifier (VBM) and the Meaningful Use (MU) legacy programs of the past. The program premiered in 2017 and is now entering its 3rd year in 2019.
New in 2019
Physical and Occupational Therapists are newly included Eligible Providers and must report if they meet eligibility thresholds.
Am I required to report?
Probably.
Now, for the first time, PT/OT therapists are included in the MIPS program for 2019. That means that if you meet ALL the eligibility thresholds found below, you must report MIPS or face a penalty.
Refer to the table below to identify if your practice meets the Required Participation criteria or Opt-In Participation criteria.
| Required MIPS Participation If you meet All in a 12-Month period |
Opt-In MIPS Participation If you meet ONE or TWO in a 12-month period1 |
|---|---|
| Billed $90K in Medicare Part B allowed charges for covered professional services | Billed $90K in Medicare Part B allowed charges for covered professional services AND/OR |
| Provide care to 200 Part B-enrolled Medicare beneficiaries | Provide care to 200 Part B-enrolled Medicare beneficiaries AND/OR |
| Provided 200 covered professional services under the Physician Fee Schedule (PFS) to Medicare Part B beneficiaries | Provided 200 covered professional services under the Physician Fee Schedule (PFS) to Medicare Part B beneficiaries |
1 Opt-in participation: You may opt-in as an individual clinician or as a group if you exceed one or two of the three threshold criteria (either as a group or individual).
Should I report?
You may have noticed that you will not know with absolute certainty that you are required or may report because the year hasn’t happened yet. So, unless meeting the criteria in Figure A is highly unlikely, it is a best-practice to get started and be ready to report.
- With a 7% penalty applied to eligible therapists who do not report, it is in your best interest to at a minimum, avoid that penalty.
- 30 points meets the minimum to allow your practice to be neutral. IMPORTANT: Being Neutral is still avoiding giving up 7% of your billing!
- 31–74 points is a small upward adjustment. 75+ points is exceptional performance bonus territory.
Remember, successful reporting isn’t just about getting a bonus! There are bigger penalties each year that you want to try and avoid!
Impact on the Bottom Line
Practice 1
150 Providers
$12,043,651 in Part B Claims in 2019
MIPS Impact = +/- $843,055.57
Practice 2
25 Providers
$2,672,866 in Part B Claims in 2019
MIPS Impact = +/- $187,100.62
Practice 3
5 Providers
$481,746 in Part B Claims in 2019
MIPS Impact = +/- $33,722.22
These figures are based on a +/- 7% adjustment.
Non-participation in 2019 will automatically result in a -7% adjustment in 2021.
