The holiday season is right around the corner, and while this time of year is always ripe for celebration—and rightfully so—the elimination of PQRS doesn’t mean you should bust out the confetti and noisemakers just yet. Wait, therapists no longer have to report PQRS data to Medicare—and that’s a bad thing? While that stand-alone decision may give you all the holiday feels, it should also give you pause: the truth is that because rehab therapists are excluded from the Merit-based Incentive Payment System (a.k.a. MIPS, Medicare’s PQRS successor) for the first two years of the program, they won’t see any of the benefits of participating in that program. So, compared to their MIPS-eligible colleagues, rehab therapists’ pile of gifts from Santa Claus (or Hanukkah Harry) could be significantly smaller—especially as payment rates become increasingly data-driven. Talk about getting lump of coal in our collective stockings!
Fortunately, by taking a backseat and learning the intricacies of the MIPS and its parent policy, the Medicare Access and CHIP Reauthorization Act (MACRA), before joining the party, therapists have the advantage of amassing a lot of collective industry knowledge. And that means they have a greater chance for success out of the gate (even with a late start). Here are four things to consider now so you’re ready to participate in Medicare’s brand spankin’-new quality data reporting program as soon as you’re able to do so:
1. Brace your clinic for alternative payment models.
Much like the change of seasons can throw you for a loop—constant sore throats and runny noses, anyone?—replacing the fee-for-service (FFS) model with a pay-for-performance system is quite the undertaking. But while providing quality care at a lower cost is something we can all applaud—it’s certainly a major theme in the rollout of MIPS—the APTA believes the industry must raise its collective voice to shape future payment models in order to benefit from this paradigm shift. That’s because the US Department of Health and Human Services (HHS) has already set a goal to:
- Base 30% of all Medicare FFS on alternative payment models by year’s end (which it has already done)—and increase that proportion to 50% by 2018.
- Link 85% of FFS payments to outcome measures by year’s end—and bump that percentage to 90% by the end of 2018.
Now, discussion of alternative payment models (APMs) in Medicare’s Final Rule is minimal, but the APTA believes it prudent that industry advocates have a place at the table once the rule is widened. "It's APTA’s hope that there will be the opportunity to work with the federal government to create new APMs that will bolster participation," said APTA Director of Regulatory Affairs Roshunda Drummond-Dye. "The bottom line is APTA and the profession have a lot of work to do in this area."
2. Don’t sit back and wait until 2019.
In this case, having a wait-and-see attitude won’t do the therapy community any favors. When we sit back and rest on our laurels, we limit our growth and fail to evolve. In truth, rehab therapists don’t—and shouldn’t—have to wait until 2019 to take part in MIPS. CMS has indicated that it will allow non-eligible providers to participate in MIPS during the 2017 and 2018 reporting years on a voluntary basis (in essence, it’s a no-pressure opportunity to fine-tune your quality reporting skills—without the threat of a negative payment adjustment hanging over your head). Think of it like muscle memory: the more you work at it, the easier it becomes, and the greater the results you’ll eventually see. Now, no one likes being labeled an overachiever, but participating in MIPS on a voluntary basis could also have a big—and positive—impact on the industry (my colleague Brooke Andrus breaks it down here). Plus, it’s another way for the industry to stay proactive on this front and determine whether it can help shape future programmatic requirements.
Unfortunately, CMS failed to provide any specifics about voluntary participation in its Final Rule—and what, if any, incentives rehab therapists will receive for doing so. While the details are a bit fuzzy right now—actually, quite opaque—we strongly believe therapists should take any opportunity to stay in the habit of collecting quality patient date; no one wants to lose their edge—or have their quality reporting skills go dormant.
So whether your clinic has always been steadfast in reporting PQRS data to Medicare, or you haven’t bothered with these obligations in the past, going forward, it’ll become increasingly important to get in this habit so you can set yourself up for success in the future. Sure, this means more work for you and your staff, but why put off now what you’ll surely have to do later? Look to industry leaders like the APTA for advice—and carpe MIPS (seize the MIPS; that’s MIPS, not Moops).
3. Get an EMR partner you can trust.
Technology continues to make our lives easier; indeed, EMRs certainly simplify a lot of processes for rehab therapists—especially when it comes to regulatory compliance. And once therapists become eligible for MIPS, they may need an EMR just to comply with the requirements. After all, MIPS sets standards for the EMRs that eligible professionals use to report quality patient data (and FYI, WebPT is committed to keeping our platform fully compliant with any rehab therapy-applicable regulations that come down the pike). According to the APTA, MIPS also calls for EMRs to meet specific criteria in the “advancing care information” performance category under MACRA. So, if your clinic is in the market for an EMR, you’ll sleep better at night knowing your system has compliance on lock. In the words of a great leader in a far-off galaxy, “choose wisely, you must, young padawan.”
4. Know that data is our path to greatness.
For years, industry leaders have worked feverishly to get rehab therapists on board with quality data collection and submission. But all that effort could be for naught if therapists decide to go on a data-reporting sabbatical and wait until 2019 to restart their efforts. As WebPT President and Co-founder Heidi Jannenga has explained, the fact that PTs, OTs, and SLPs won’t be eligible for MIPS right off the bat shouldn’t be an invitation to sit on the sidelines.
Instead, therapists should be chomping at the bit to collect more patient data in order to better validate “the efficacy of their treatment” and objectively demonstrate why their work matters. While the financial incentive may not be there yet, Jannenga believes data collection—whether or not it’s part of a mandated Medicare program (outcomes tracking, anyone?)—is the bridge toward achieving “more money, more patients, and more respect within the healthcare community.”
While the blissful holiday season and the rollout of new CPT codes (eek!) will no-doubt continue to be top-of-mind for rehab therapists in the coming weeks, getting a head start on MIPS should also be on your radar—during the holiday season and beyond. And before you resolve to shun MIPS altogether until 2019, think about some of the possible consequences of forgoing quality data-collection. Not convinced it’s worth your time and energy? Tell us why in the comment section below.