CMS is ringing in 2020 with some regulatory changes—including tweaks to everyone’s favorite quality payment program: MIPS. Luckily, you don’t need to whip yourself into a compliance frenzy and navigate your own way through a stormy sea of new, changed, and deleted rules and guidelines. That’s because, while the program has changed a little bit, it’s still the same ol’ MIPS—just like an origami swan is still a piece of paper. It’s just been folded and transformed into a slightly different shape.
MIPS Overview
Now, before we jump into the 2020 MIPS changes, let’s address the elephant-sized question in the room: “What, exactly, is MIPS?” Well, MIPS is the Merit-based Incentive Payment System—a Medicare program that uses payment adjustments to reward (or penalize) medical providers based on the quality of care they provide. MIPS has a lot of moving parts—and it definitely comes with its fair share of confusing rules—but MIPS-eligible therapists only have to worry about two of the program’s four parts. For a detailed rundown of everything MIPS, check out this in-depth guide to the program.
I want to preface the rest of this article by saying that I’m only going to cover the parts of the program that have changed for 2020. That means anything I’ve left out (like the low-volume threshold or the opt-in requirements) should be exactly the same as last year. (If you’re not sure what the requirements were for 2019, refer to this blog post.) If you’d like to double-check that a specific program requirement will stay the same, feel free to leave a comment at the end of the post!
Performance Threshold
The MIPS performance threshold has risen to new (slightly steeper) heights for the 2020 performance year. MIPS participants must score a total of 45 MIPS points in order to successfully avoid a negative payment adjustment. This scary-looking change may be a full 15 points higher than last year’s threshold, but it shouldn’t be anything to stress about. In the 2017 performance year, 71% of MIPS participants scored 70 points or more—so that 45-point threshold shouldn’t be too difficult to meet.
Additionally, CMS decided to give the exceptional performance bonus threshold (now called the additional performance threshold for exceptional performance) its own boost. In 2020, MIPS participants will have to score 85 points (up from 75) in order to qualify for this additional bonus.
Payment Adjustments
The next notable adjustment to the MIPS program that rehab therapists need to know about is the change to participants’ payment adjustments. In 2020—and for the foreseeable future—MIPS participants who do not meet the performance threshold will see a negative adjustment ranging from 0% to -9%. However, those who surpass the performance threshold could see a positive adjustment ranging from 0% to 9%.
Here’s how it’ll shake out—in chart form.
| Overall MIPS Score | Medicare Payment Adjustment |
| 0.0–11.25 points | -9% |
| 11.26–44.99 points | -9% to -0.01% |
| 45.00 points | 0% |
| 45.01–84.99 points | 0.01% to 9% |
| 85.00–100 points | 0.01% to 9% PLUS an additional 0.5% to 10% bonus |
To clarify, the potential exceptional performance adjustment (which could be an additional 0.5% to 10% bonus depending on budget constraints) will not change.
Quality Category
The quality category (which was complicated enough during 2019) is seeing the most rehab therapy-relevant changes in the upcoming year. First and foremost, the reporting requirements will be a little more stringent than they were in 2019. MIPS participants who report via QCDR or registry (like our Members) will have to report measures with 70% completeness for all applicable patients—regardless of payer. MIPS participants who report via claims will also have to report measures with 70% completeness—but only for all applicable Medicare Part B patients.
Last year, CMS only required 60% data completeness, so the requirements for 2020 are slightly more arduous than last year’s. However, CMS claims that data completion rates actually averaged around 80% with the legacy PQRS program (the original source of the quality category); so, in theory, this shouldn’t be a burdensome change.
Deleted PT and OT Measures
CMS tidied up its measure list for the 2020 performance year, nixing two of the measures that appeared in the 2019 PT/OT specialty measure set. The first deleted measure (223: Functional Status Change for Patients with General Orthopedic Impairments) got tossed because it was “less meaningful” than other outcome reporting measures. CMS gave the other measure (131: Pain Assessment and Follow-Up) the axe because it “may have the unintended consequence of encouraging excessive prescribing of pharmacologic therapies to assist with pain management.” (In other words, CMS realized that physicians might have prescribed opioids to complete this measure. Whoops!)
New PT and OT Measures
Luckily, even though PTs and OTs lost a couple reportable measures, they were given six new ones:
- 181: Elder Maltreatment Screen and Follow-Up Plan
- 478: Functional Status Change for Patients With Neck Impairments
- 282: Dementia: Functional Status Assessment
- 283: Dementia Associated Behavioral and Psychiatric Symptoms Screening and Management
- 286: Dementia: Safety Concern Screening and Follow-Up for Patients with Dementia
- 288: Dementia: Education and Support of Caregivers
New SLP Measures
And speaking of specialty measure sets, SLPs finally got one of their own. It contains the following measures:
- 130: Documentation of Current Medications in the Medical Record
- 181: Elder Maltreatment Screen and Follow-Up Plan
- 182: Functional Outcome Assessment
- 226: Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention
If SLPs are itching to report outside of this set, they can also report measure 134: Preventive Care and Screening: Screening for Depression and Follow-Up Plan.
Improvement Activities Category
The improvement activities category will stay mostly the same for 2020—unless you plan to participate in MIPS as a group. In 2020, for a group to attest to completion of an improvement activity, 50% of the NPIs reporting in the group must complete the activity. In other words, if you have six therapists reporting together as a group, then three of those therapists must complete an improvement activity in order to attest to it. In 2019, only one of those therapists had to complete an activity for it to apply to the whole group—so this category will take a little more legwork this time around.
The improvement activities themselves didn’t see too many changes—although CMS removed 15 activities, modified seven, and added two. There are still more than 100 available activities, though, so it shouldn’t be too difficult to find some that apply to your practice. For a full list of the 2020 improvement activities, check out the QPP resource library.
So, do you feel prepared to tackle MIPS in 2020? We here at WebPT still believe that MIPS participation isn’t necessarily right for every practice—but with the 2021 and 2022 Medicare cuts looming, it might be the only way to recoup some of the money Medicare is taking away. Do you know what your practice is going to do?
