Physical Therapists and the Quality Payment Program

Understanding the QPP Participation

Physical therapists (PTs) are now an integral part of the Quality Payment Program (QPP). This participation is mandatory, as there is no option for withdrawal. To navigate the complexities of value-based care effectively, PTs can utilize Medicare MIPS reporting through a MIPS Qualified Registry or an Electronic Health Record (EHR) system. They primarily have the choice between the Merit-Based Incentive Payment System (MIPS) and an Advanced Alternative Payment Model (Advanced APM). Despite the significant influence of APMs, MIPS remains the preferred program among eligible PTs.

Voluntary Participation for Low-Volume Therapists

PTs who do not meet the low-volume threshold (LVT) now have the option to participate voluntarily. This participation is crucial for preparing for future changes in the healthcare landscape.

Medicare MIPS Reporting for Quality and Improvement Activities

Performance Categories Requirement

Fortunately for PTs, they are not obligated to report in all four performance categories but instead are required to focus on just two: Quality and Improvement Activities (IAs). This streamlined approach reduces the number of measures they need to report to the Centers for Medicare & Medicaid Services (CMS), allowing them to maximize their scores without the risk of burnout.

Consequences of Non-Reporting

Annual reporting against Quality measures will determine the final score. Failure to report can result in negative payment adjustments. The most efficient way to handle Medicare MIPS reporting is through certified electronic health record technology (CEHRT) or MIPS Qualified Registries, such as P3 Healthcare Solutions.

Advanced APM Participation Track

Limitations on Reporting

PTs opting for the Advanced APM participation track cannot pursue Medicare MIPS reporting, as they must choose one track at a time. However, if their reporting results meet the benchmarks, they can expect an additional reward of +5% to their Medicare earnings from 2019. High performers may also have the opportunity to earn bonus rewards from a $500 million pool. The recent removal of functional limitation reporting (FLR) signifies a positive shift by CMS in support of PTs and their role in value-based payment systems.

P3Care Reports for PTs and PTAs

Data Submission Process

Submitting MIPS data is distinct from other data submissions, requiring the National Provider Identifier (NPI) and Tax Identification Number (TIN) along with account creation on the QPP portal. Health IT consultants at P3Care facilitate this process, ensuring accuracy is paramount since submissions occur only once.

Telehealth Considerations

The final rule currently does not permit PTs to be reimbursed for Telehealth services. While physicians and specialty-specific clinicians are eligible for virtual check-ins and timely reimbursements, P3Care advocates for Telehealth initiatives for PTs and PTAs, especially in light of its necessity highlighted during 2020.

Direct Submission Method

Registry Method for Submission

PTs may utilize the registry method for direct submission, requiring the collection type to be MIPS Clinical Quality Measures (CQMs). Effective Medicare MIPS reporting in 2019 hinges on the accuracy and selection of high-scoring measures. Generally, outcome measures and high-priority measures are vital for achieving bonus-worthy scores, translating into financial rewards.

Submission Options for Small Practices

For smaller practices, individual clinicians and groups can gather and submit measures for Quality through Medicare Part B claims. Groups comprising 25 or more clinicians may opt for the CMS web interface for Medicare MIPS reporting.

Deadline for the QPP 2019 Program

MIPS eligible clinicians can submit data for 2019 until March 31, 2020. If using claims for submission, the deadline extends to 60 days after the end of the performance year.

Improvement Activities (IA)

Weight and Reporting Considerations

For PTs and Occupational Therapists (OTs), the Improvement Activities category holds a weight of 15% in the overall score, equating to 40 points. Only the top performers will achieve this score. Recommended improvement activities for reporting to CMS include:

– Care Coordination
– Patient Safety
– Beneficiary Engagement
– Participation in APM
– Achieving Health Equity
– Emergency Preparedness and Response
– Population Management

Reporting Format Requirements

When reporting, it is essential to adhere to the following classifications:

– Two high-weighted measures
– One high-weighted measure and one medium-weighted measure
– Four or more medium-weighted measures

After selecting the activities for submission, PTs are prepared for Medicare MIPS reporting through Qualified Clinical Data Registries (QCDR), Qualified Registries, or an EHR system. Those wishing to manage the MIPS attestation process independently can do so by logging into the QPP portal.

Engagement and Feedback

Do you believe you can gather data and report independently, or would it be more beneficial to engage third-party intermediaries? Share your thoughts in the comments below; we would love to hear from you.