It’s been more than a year since CMS added rehab therapists to the Merit-Based Incentive Payment System (MIPS)—but it’s still the talk of the town. Providers are trying to decide if participation is right for them, but weighing the pros and cons of MIPS is proving to be a little more difficult than expected. Perhaps unsurprisingly, the structure CMS chose for MIPS is complicated, which makes successful participation difficult at best. This problem is only amplified in small practices. Their revenues are lower—which means the stakes are often higher, as a bungled MIPS participation effort could seriously strangle a clinic’s cash flow. 

So, should small practices participate in MIPS?

Maybe. There are certainly benefits to MIPS reporting, but they’re not guaranteed—and it can be tough for small practices to check all the boxes required to earn a worthwhile incentive. But, MIPS participation is currently the only official way to offset CMS’s recently-announced reimbursement cuts. And considering that the stakes may be even higher in the future—think universally mandated participation and a steeper penalty—it may behoove small practices to get on board with the program sooner rather than later. But before we get into a detailed cost-benefit analysis, let’s cover the basics of the MIPS program.  

What is MIPS?

MIPS is a budget-neutral quality payment incentive program. It’s CMS’s most recent attempt at improving the Medicare patient experience by motivating healthcare providers to improve their care. Providers who perform well can earn a positive adjustment of up to 9% on all of their Medicare claims for a whole year—and providers who perform really well can earn a 0.5–10% adjustment on top of that. 

But, even though that cash incentive sounds pretty rad, it comes with a serious catch. Providers who participate in the program and perform poorly can lose a heap of money—up to a negative 9% adjustment on all Medicare claims. Those reductions directly fund the reimbursement bumps high performers receive—thus keeping the program budget-neutral. 

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What are the benefits of MIPS reporting? 

A positive adjustment could help mitigate the impact of the 8% and 15% cuts. 

If MIPS has been the talk of the town, then the sweeping 8% cut to rehab therapy reimbursements—as well as the 15% reduction to assistant-provided services—has been the talk of the nation. Even though it’s been months since rehab therapy providers received word of these reductions, the industry is still reeling. Therapists—especially those who see a high volume of Medicare patients—aren’t exactly sure how they’re going to adapt (or even survive) once these cuts go into effect. 

That’s why we’ve mentioned (a couple of times now) that therapists may need to take a more serious look at MIPS participation in 2020. Sure, the program comes with its fair share of risk, but it may be the only way for therapists to recoup some of the money CMS is planning to take away. Most MIPS incentive payouts won’t fully cover the impending reductions, but it’s something. 

It may behoove therapists to practice MIPS reporting before it becomes mandatory.

Some compliance experts predict that MIPS will eventually become mandatory for all healthcare providers. While we can’t say for certain that this will happen, it’s a possibility—and what we can say with 100% certainty is that the program has become increasingly difficult each year since its inception, and it will continue to do so for at least a couple more years. 

So, while MIPS participation may not sound terribly appetizing to some providers in 2020, it’ll be a much tougher pill to swallow once the performance bar has nearly doubled (as it is slated to do). It may behoove therapists to familiarize themselves with the program before the stakes get even higher. Most participants have earned positive scores so far, and earning enough points to avoid a negative adjustment seems manageable—for now. 

CMS is awarding bonus points and providing special reporting accommodations to participants in small practices.

CMS recognizes that reporting in a small practice is way different (and way more difficult) than reporting in a large enterprise organization. Small clinics don’t always have the resources (e.g., MIPS reporting software) to fully support participation, and it’s often more difficult for therapists in these settings to find the time to complete extra reporting. That’s why CMS is offering bonus points and reporting accommodations to clinicians who work in small practices.

Small-practice providers are eligible to receive six bonus points in the Quality category, and they will earn double points in the Improvement Activities category—effectively cutting the workload for that category in half. 

What are the drawbacks of MIPS reporting?

When it comes to MIPS participation, the risk is high and the reward is minimal. 

MIPS is a zero-sum game—at least from CMS’s perspective. CMS won’t shoulder the expense of the program, so every incentive payment comes directly out of the pockets of the providers who perform poorly. The problem is that, during the first two years of the program, the vast majority of participants (I’m talking 9398%) have earned a positive adjustment of some kind. This has kept the incentive payments extremely minimal (think 0.00–1.88% max), while penalties soared to the opposite extreme. 

It’s a little bit harder for small practices to perform well. 

Though most MIPS participants from small practices have successfully participated in the program, they’ve done so at a significantly lower rate than the general MIPS participant pool. To give you an idea of what I mean, only 74–84% of participants from small practices have earned a positive payment adjustment in the program thus far. Don’t get me wrong—those are still great numbers, but they’re a far cry from the 93–98% overall success rate. 

What are my MIPS reporting options?

You can report as an individual or as a group.

If the idea of solo MIPS participation is making you sweat, take heart! You don’t have to go it alone. In fact, you can choose to report as a group with the other clinicians in your practice—as long as y’all have reassigned your Medicare billing rights to your clinic’s TIN. When you report as a group, CMS amalgamates your work and evaluates and scores your group’s performance as a whole. In this scenario, everyone receives the same MIPS adjustment—even if some individuals perform better than others. 

You can report via claims or Qualified Clinical Data Registry (QCDR). 

When you choose to report for MIPS, you can choose to do so on paper (i.e., via claims) or digitally (i.e., via QCDR or verified registry). Claims reporting is the most burdensome option, as you have to do all the work by hand (including your risk adjustment calculations). However, for small practices that can’t afford to purchase MIPS reporting software, this may be the only viable option. 

Alternatively, you can report digitally via QCDR or verified registry. These pay-to-play software solutions typically integrate with your EMR and do all the work for you. They’ll help you submit your measures to CMS, and they may even automate your risk adjustment calculations. 

You can practice reporting and take money completely out of the equation. 

If full MIPS participation feels too risky for you or your clinic, you do have the option to voluntarily report for MIPS. If you choose to report voluntarily, then you’ll report MIPS data and receive a score as if you were a full-fledged participant—but you won’t be subject to any of the financial incentives or penalties. Voluntary reporting is a happy-medium option, because clinicians can practice MIPS and determine if participation is really right for them without diving in head-first.  


At the end of the day, most therapists who work in small practices aren’t mandated to participate in MIPS—and reporting might not necessarily be in their immediate interests, either. But, that doesn’t mean that they should simply kick the MIPS can down the road. Participating now could help them lay a strong foundation for the future—and who doesn’t want that?