The trickiest thing about the Merit-Based Incentive Payment System (a.k.a. MIPS) for rehab therapists is that most PTs, OTs, and SLPs are not required to participate in the program—at least, not yet. That means every year, when it comes time to choose whether or not to opt into MIPS, rehab therapists are left wondering, “Is MIPS worth the trouble?”
Calculating your MIPS return on investment (ROI) can be a tall order, especially because how you report your data can change the whole equation. It’s worth noting that both methods of reporting—as an individual or as a group—have pros and cons. Neither option is wholesale better than the other; it all depends on individual clinician and clinic preference.
So, let’s talk about that. Let’s look at the pros and cons of reporting as an individual or as a group—and you can make an informed decision on which MIPS reporting option is best for your clinic. (Need a MIPS refresher? Check out this guide to MIPS before continuing through this article.)
In order to opt in as an individual in the MIPS program, a provider needs to serve a certain volume of Medicare beneficiaries. In other words, to participate in MIPS a provider must meet at least one of these criteria:
- Billed Medicare for more than $90,000 in Part B allowed charges;
- Provided care to more than 200 Medicare Part B beneficiaries; and/or
- Provided 200 or more covered professional services under the Physician Fee Schedule.
(To learn more about MIPS participation mandates and opt-in criteria, check out this guide.)
If a clinician chooses to report for MIPS as an individual, then that clinician’s final MIPS score—and subsequent payment adjustment—hinges solely on individual performance. The clinician is individually responsible for completing all requisite quality measures and improvement activities and submitting that information at the end of the performance period. Additionally, the score they earn will follow them to their next practice group if they change employers.
Though reporting for MIPS as an individual may feel like a daunting task, it does come with some perks.
You don’t have to rely on other clinicians to get a good score.
Remember back in school when teachers and professors assigned group projects? Those projects always elicited a special kind of dread, because you never knew if you’d get paired with partners who cared about the class or with partners who skated by with minimal effort. That’s why the best teachers gave students the option to create groups of one—so they could sidestep the problems of group work altogether.
Think of individual reporting like you’re opting out of a group project and choosing to do the whole thing yourself. You may have a little more work to do, but you don’t have to worry about monitoring your teammates and ensuring they do their part to earn a high score. As an individual reporter, your score is calculated based on your own merits and efforts.
You’re exempt from participating in the promoting interoperability and cost categories.
Ever since they became MIPS-eligible clinicians, PTs, OTs, and SLPs have been exempt from two of the four MIPS categories: promoting interoperability and cost. As an individual MIPS participant, a rehab therapist runs no risk of being scored in those categories. The same may not hold true for MIPS participants who report in a group. (More on that in a bit.)
You can limit the administrative burden of MIPS to a select few therapists.
Some practices that are new to the MIPS experience prefer to limit participation to mandated individuals so they can learn about the impact on productivity. Think of it like putting your toes in the water to test the temperature before diving into the pool. Approaching MIPS in a cautious, measured way may allow you to experiment with adjustments to workflow and staff roles before involving the entire clinic in the process.
Though individual MIPS reporting has its benefits, it’s not all sunshine and daisies.
You can’t get any help with completing quality measures or improvement activities.
Think back to that “group project” metaphor I mentioned a couple sections ago. While reporting as an individual means you won’t have to pull extra weight for your teammates, it also means that you won’t be able to divide and conquer your MIPS to-dos. Individual MIPS participants are responsible for completing all of their quality measures and improvement activities on their own.
You won’t have your quality measure “pick of the litter.”
When selecting and reporting quality measures, individual MIPS participants are restricted by CMS’s measure eligibility designations. (Basically, CMS only allows MIPS participants to report measures that are designated as applicable to their specialty.) However, that means some individual MIPS participants may get stuck reporting a measure that they’re not equipped to perform well.
SLPs, for instance, only had four measures included in their specialty measure set in 2020:
- 130: Documentation of Current Medications in the Medical Record;
- 181: Elder Maltreatment Screen and Follow-Up Plan;
- 182: Functional Outcome Assessment; and
- 226: Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention.
Because there are only four measures in this set, participating SLPs must report on all four—regardless of how well they align with their practice or patients.
Your returns could be relatively small considering the effort it takes to participate.
Historically speaking, positive MIPS payment adjustments have been low—even for the highest-scoring participants. In 2017, the highest positive MIPS adjustment (including the bonus for exceptional performance) was 1.88%. In 2018, the highest adjustment was only 1.68%, and in 2019, the highest adjustment was 1.79%. These annual adjustments may increase—especially once CMS rescinds its COVID-19 MIPS flexibilities—but I wouldn’t count on it. So far, a vast majority of MIPS participants have earned “exceptional” scores each year, thereby reducing the amount of money that CMS can hand out as an incentive.
Between the cost of purchasing a MIPS reporting solution and the employee hours it takes to report, the monetary ROI of individual MIPS participation isn’t all that compelling.
In order to report for MIPS as a group, all MIPS-eligible clinicians must reassign their Medicare billing rights to a single tax identification number (TIN). As a whole, the group must meet at least one of the volume threshold criteria. If the group surpasses the threshold and opts in, then all clinicians who bill under that TIN will work together to complete MIPS and earn a final MIPS score. The corresponding payment adjustment will apply to each member of the group.
Remember that participating in MIPS as a group is always optional. CMS will never mandate a group to participate in the program; mandatory participation is assessed only at the individual level. However, if your clinic colleagues choose to report as a group, and all your Medicare billing rights are assigned under one TIN, then you are automatically tied to the MIPS group and its score (as well as its corresponding payment adjustment).
Reporting as a group can actually be a huge boon for MIPS participating providers.
You can split up the MIPS workload.
Reporting for MIPS as a group lessens the administrative workload of participation—at least a little bit. Instead of each group member having to individually report and submit six quality measures, the group is only required to report six measures in total. Multi-specialty practices can further divvy up the workload by funneling their attention and resources toward select members of the group.
For example, let’s say there’s a clinic that employs an MD, a PT, and an SLP, and all three of those providers decide to participate in MIPS as a group. Hypothetically, the group could report three quality measures that apply to the physician, two measures that apply to the PT, and one measure that applies to the SLP, thus lessening the workload for everyone.
And that’s just the quality category. To comply with the requirements for the improvement activities category, at least 50% of clinicians in a group have to complete—and then attest to completing—an improvement activity. So, in the aforementioned example, only two of the three group members would actually have to participate in this category.
You may have more flexibility with choosing your quality measures.
As I mentioned above, not every measure a group chooses to report has to apply to every member of the group. That gives groups (especially multi-specialty groups) more flexibility when selecting their measures. While providers participating as individuals are often beholden to whichever measures are available to them (as noted with the SLP example in the Individual Reporting section above), groups can maximize their MIPS score by picking and choosing the measures for which they are the most likely to receive the highest possible score.
Going back to that hypothetical clinic that employs an MD, a PT, and an SLP: If the MD really struggles to succeed in MIPS but pulls in a huge number of Medicare dollars, the clinic could compensate for the MD’s poor performance with the excellent performance of his or her PT and SLP peers. CMS counts only the top six performing measures reported by a group, so if the PT and SLP performed exceedingly well on six measures, CMS would count those scores instead of the MD’s—thus saving the group’s score.
Your positive payment adjustment could boost clinic revenue in a more consistent way.
As I already mentioned, MIPS payment adjustments have been minimal at best. The largest positive adjustment awarded to date was a whopping 1.88% in 2017. While this adjustment would be nominal if applied to one provider’s Medicare earnings, it could meaningfully improve a clinic’s budget when applied to an entire group’s Medicare earnings. And remember, non-mandated individuals can participate in the program by reporting with an eligible group. So, you could potentially secure more positive adjustments for more clinicians by roping the entire clinic into reporting.
If you’re in charge of planning your clinic’s budget, then it may behoove you to push for group reporting in your practice. Because all members of a group receive the same score (and therefore the same payment adjustment), it’s much easier to predict how their MIPS performance will affect the clinic’s overall budget. On the other hand, if all clinicians report as individuals, then you have to forecast how each individual’s potential adjustment will affect that individual’s specific Medicare reimbursements—and then apply those estimates clinic-wide. Yikes.
Group reporting may sound like a walk in the park, but it definitely has its drawbacks.
You have to rely on the performance of others.
When participating in MIPS as a group, you have the flexibility to choose the measures that work best for your clinic and providers. That could mean selecting the measures that are the easiest to complete—or the ones for which you can reliably secure high scores. Either way, you, as an individual contributor, may not be able to assist with some of those measures. That means we’re back to that pesky group project analogy. You have to rely on the other members of your group to pull their weight. That can be stressful—especially for Type A people like myself. After all, if performance goes sour, then the whole clinic could suffer a financial hit.
You may lose your exemption status in the promoting interoperability and cost categories.
As a rule (at least for now), PTs, OTs, and SLPs are exempt from the promoting interoperability and cost categories—and instead are scored only in the quality and improvement activities categories. However, if rehab therapists report in a MIPS group that contains providers who are not exempt from these categories (e.g., in a POPTS practice), then they lose their category exemption status.
One note: If rehab therapists belong to a MIPS group that contains only providers who are also exempt from the promoting interoperability and cost categories, then those therapists will retain their exemption status.
So, what do you think? Which reporting option is best for you? Ultimately, the decision is yours, and yours alone. In the meantime, though, if you have any questions about how MIPS works, feel free to drop ’em below. Our team will do its best to help you out.