It’s official: rehab therapists are just a sashay away from exiting the PQRS dance floor. That’s because last week, the Centers for Medicare & Medicaid Services (CMS) issued a proposed final rule that, if adopted, will put into effect the Medicare Access & CHIP Reauthorization Act of 2015 (MACRA). And that, in turn, will give the green light to the Merit-based Incentive Payment System (MIPS), a brand spankin’-new quality data reporting program that consolidates PQRS, the value-based modifier, and Meaningful Use. The only problem: physical, occupational, and speech therapists aren’t invited to the MIPS party—not for the first two years of the program, anyway.

Cue unanimous reaction from Medicare-jaded therapy providers: “Wait, why is that a problem?” Sure, on the surface, rehab therapy’s exclusion from the introductory years of MIPS might seem like a cause for celebratory fist-pumping—especially considering that, with the elimination of the PQRS program, rehab therapists are essentially off the hook for quality data reporting in 2017 and 2018. Plus, it’s always better to be fashionably late to any party, right? Who wants to deal with those awkward first few minutes when the DJ can’t figure out the sound system and the food isn’t out yet?

Unfortunately, in this case, tardiness doesn’t necessarily give providers a leg-up at the hors d'oeuvres table. In fact, by the time PTs, OTs, and SLPs become eligible professionals—2019, according to the proposed rule—they could be left fighting for the scraps. In this letter to CMS Acting Administrator Andy Slavitt, APTA President Sharon Dunn provides several reasons why therapists’ inability to participate in MIPS from the get-go will negatively impact the entire industry, including the following:

Unwrapping MIPS and the Final Rule: How to Prepare for 2019 - Regular BannerUnwrapping MIPS and the Final Rule: How to Prepare for 2019 - Small Banner

1. The role quality data plays in payment determination and distribution will only continue to grow in significance.

Back in 2015, the US Department of Health and Human Services (HHS) announced its goal to:

  • Base 30% of all Medicare fee-for-service (FFS) on alternative payment models by the end of 2016.
  • Increase that proportion to 50% by 2018.
  • Link 85% of FFS payments to outcome measures by the end of 2016.
  • Bump that percentage to 90% by the end of 2018.

Since then, the federal government has definitely put its money where its mouth is: this past March, HHS announced that it had already surpassed the 30% threshold listed in that first bullet.

MIPS represents one more step toward tying virtually all Medicare payments to some type of value measure, which begs the question: if rehab therapists aren’t allowed to participate, how much of the payment pie will they miss out on? “Given the current healthcare payment environment and the focus on outcome-based payment models we believe the exclusion of physical therapists from the MIPS program in the initial years is a step backwards, and may have many unintended consequences,” Dunn argued in her letter. Chief among those consequences: the continued undervaluation of physical therapy services—which could result in low-ball reimbursement rates.

2. Rehab therapists will get out of the habit of reporting quality data—and it could be tough for them to rebound.

The APTA and other industry organizations and leaders have worked hard to get rehab therapists on board with quality data collection and submission. This was especially evident in the lead-up to 2013, which was the first year PQRS-eligible professionals were required to report satisfactorily in order to avoid a negative payment adjustment. But, all of that effort could be in vain if rehab therapy professionals backslide in reporting compliance after their two-year break. And for Dunn, that’s a very real worry: “APTA is concerned that PTs will struggle to return successfully into the quality reporting space in 2019 under the constructs of an entirely new program after this two year hiatus,” she explained in the previously cited letter.

This would be especially unfortunate considering that, according to Dunn, the PQRS participation rate for PTs and OTs in 2013 was 62.6%—more than 10% higher than the national average of 51.2%. That’s why, if CMS goes through with its plan to exclude certain providers from the first couple years of MIPS, Dunn and the APTA strongly recommend that CMS “continue to incentivize participation in quality reporting programs (e.g., PQRS) for PTs and the other non-physician providers that were excluded from the initial group of EPs in MIPS.” One way CMS could do this, according to Dunn: allow MIPS-excluded professionals to continue reporting PQRS and then credit that participation toward those providers’ MIPS performance when they become eligible in 2019.

3. The lack of available data for rehab therapists could unfairly skew the perceived value of rehab therapy.

We’ve said it before, and we’ll say it again: the only way rehab therapists can confidently and effectively assert their value as first-choice providers and care coordinators is through the collection and presentation of objective data. And the more opportunities they have to do that—especially ones that put them on a national stage alongside their physician and surgeon colleagues—the better. As it stands, though, MIPS will allow those other providers two full years of data reporting before therapists even complete their first measure, which means the data sets for other specialties will be larger—and thus, stronger—than those for rehab therapy disciplines. “APTA is concerned about the public perception of physical therapists during the 2017 and 2018 years when they are not participating in the MIPS program,” Dunn wrote in her letter. Not only could therapists’ lack of participation translate as apathy—or worse, resistance—toward quality data collection efforts, but it also could lead to biased data comparisons until therapists are able to amass enough data to “catch up” to the rest of the data-collection pack.

So, before you use your walk to happily prance off the PQRS dance floor, think long and hard about the possible long-term consequences of going on a two-year quality data-collection sabbatical. Convinced it’s not the right move for the rehab therapy industry? Get your pen ready: once the proposed rule publishes to the Federal Register on May 9, it’ll be open to public comment for 60 days. Think therapists are better off waiting for the MIPS second wave? Tell us why in the comment section below.

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