I’ve spent an enormous amount of time researching MIPS—from digging through the 2,000-odd pages of the final rule and decoding line upon line of legalese, to participating in hour-long discussions (and dozens of email chains) with WebPT’s compliance experts. After all that researching, I feel pretty comfortable with the ins and outs of the program—as well as its benefits and drawbacks. So, let’s talk shop. Here are the pros and cons of MIPS participation:


MIPS isn’t all muck and mire—it actually has some pretty sweet draws for successful participants. So, CMS deserves some credit for trying to create a program that encourages high-quality care delivery across the health industry and throughout the entire patient experience—from treatment to cost.

WebPT Outcomes - Regular BannerWebPT Outcomes - Small Banner

MIPS provides monetary incentives.

One of the MIPS program’s biggest draws is its monetary incentives. If you (or your group) performs well under the MIPS program, you could earn a positive payment adjustment of up to 7% on all Medicare Part B claims during the payment year (which comes two years after the reporting year). And if you perform exceptionally well—like scored-more-than-75-overall-MIPS-points well—you could potentially earn another 10% in addition to the 7% adjustment. That adds up to a whopping 17% positive adjustment on every single Medicare claim over the course of the year.

And while it may be difficult to wrangle the full 17% adjustment out of CMS (more on that later), it’ll be pretty easy to stay in the positive (or at the very least, break even). The 2019 performance threshold is only 30 MIPS points out of a possible 100, so—as we illustrated with an example scenario during our MIPS webinar—you would have to bomb a category pretty badly to get saddled with a negative adjustment.

MIPS could increase the collection of vital data about the rehab therapy industry.

As WebPT President Heidi Jannenga, PT, DPT, ATC, frequently says, the best way to push the rehab therapy industry forward is to collect data and use it to demonstrate value. When rehab therapists participate in MIPS, they’re providing CMS with large-scale data that speaks to the patients they treat and the quality of care they provide. Eventually, this data could help objectively position rehab therapy as an effective—and often superior—treatment route for many chronic pain diagnoses. That data can then be used to improve rehab therapists’ reputation in the greater medical community—by pushing others to realize that therapy could be a solution to the opioid epidemic, for example.

MIPS encourages evidence-based treatment.

MIPS participants must report at least six quality measures—one of which must be an outcome measure (if available). Those who report additional outcome measures will earn bonus points—provided those measures meet the data completion standard, and the participant has met certain performance requirements. What does this tell us? CMS is placing a high priority on outcomes tracking—and I mean that pretty literally. Outcome measures are classified as “high-priority” measures.

Outcomes tracking inherently encourages evidence-based treatment (i.e., if you don’t see improvement in your patients, you will likely adjust their course of care—and apply that protocol to future, similar cases). And considering that evidence-based treatment is one of the pillars of the PT profession, MIPS seems to align with therapists’ overall goals and ethics. Plus, it could be an effective vehicle for encouraging the wider healthcare industry to adopt evidence-based practices and thus, improving the overall quality of patient care.


Though MIPS is a noble attempt to improve the healthcare industry on the part of CMS, the program is far from perfect. MIPS participation comes with some unfortunate realities that few people in the healthcare world are discussing—let alone addressing. So, let’s go down the road less travelled and unpack some of the hairier aspects of the MIPS program.

MIPS payouts probably won’t meet expectations.

That 17% positive adjustment I mentioned earlier sounded pretty good, right? Well, it’s nearly impossible for MIPS participants to secure that high of a payout—and that’s especially true for rehab therapists. Remember, MIPS is a budget-neutral program, which means that every positive payout will be funded by the negative adjustments incurred by poor performers.

Division of Payout

Because it’ll be pretty easy to meet the 2019 performance threshold (as I mentioned above), we can expect relatively few MIPS failures—and thus, a relatively small pool of money to distribute among successful participants. CMS reported that 93% of MIPS participants from 2016 earned a positive adjustment in 2018; as a result, the highest reported base adjustment was only 1.88%.

The lowest positive adjustment (and I’m not talking about the neutral adjustment) was 0.00%. In other words, some providers successfully reported MIPS and did everything they were supposed to, and they received either no adjustment, or an adjustment so small that CMS rounded it to zero. So, keep in mind that if you’re paying a vendor to help you report MIPS data and ensure compliance with the program rules, your performance bonus might not even cover the cost of participation.

Division of Exceptional Performance Bonus

Well, what about the exceptional performance bonus? Sorry to say, that’s divvied up from a flat $500 million pool. The more providers who earn that bonus, the lower the adjustment will be. And because CMS is creating more opportunities to opt in to MIPS and opening the program to more provider types, the exceptional performance payout will likely get smaller as the program ages.

MIPS is not geared toward rehab therapists.

I mentioned in the previous section that a large positive adjustment would be especially tough for rehab therapists to secure. As we wrote in our MIPS FAQ, “MIPS caters primarily to physicians.” Let’s dig into one example illustrating why that’s the case.

The Promoting Interoperability MIPS category was derived from Meaningful Use (MU): a program that never applied to rehab therapists. MU required participants to use Certified EHR Technology (CEHRT)—which is essentially an EMR that’s designed to share patient information between different practices. Because rehab therapists were excluded from MU, there are very few therapy-applicable software that classified as CEHRT.

MIPS offers bonus points to participants who use CEHRT, which ultimately means that many physicians will get those bonus points—and rehab therapists will not.

Lack of Quality Measures

When it comes to the quality category, rehab therapists—specifically SLPs—are facing a quality measure drought. There are 257 quality measures available for 2019 reporting; yet, only three of them apply to SLPs. Thus, participating SLPs have no choice but to report every single one of those measures—regardless of whether or not the measures apply to their scope of care.

MIPS reporting is often burdensome.

With its 2019 updates, CMS sought to reduce the burden of MIPS reporting—but there are some burdens it can’t quite erase. All program reporting comes with a little extra legwork—whether that’s recording quality actions to a degree you’re not accustomed to, or implementing a temporary 90-day policy that helps you check an improvement activity off your list.

The FOTO Issue

One of the largest 2019 MIPS reporting burdens for PTs and OTs is the program’s inclusion of Focus on Therapeutic Outcomes (FOTO) measures. As you might know, FOTO is a rehab therapy outcomes registry, and CMS has approved seven FOTO measures for inclusion in the PT and OT quality measure specialty sets. In fact, those are the only outcome measures available for these specialties. For those providers who have a FOTO membership, this is great news; you can complete your outcomes reporting digitally, and FOTO will send the data to CMS at the end of the year—easy peasy.

Those who are not FOTO subscribers, however, face significantly more burden. Here’s the process they must follow:

  1. Go to the FOTO website, read the measure-reporting instructions, and download all applicable surveys, codebooks, and instructions.
  2. Administer the FOTO surveys on paper and calculate the scores (including risk adjustment) by hand.
  3. Record the risk-adjusted summary score in the visit note.
  4. Use a designated spreadsheet to select the appropriate FOTO measure reporting code that indicates performance of the quality action.

That entire process is doable, yes, but consider the time it takes to complete those steps. Multiply that by multiple appointments, and remember that you’ll follow that process for multiple patients. And again, there’s no getting around the FOTO measures. PTs and OTs are required to report at least one outcome measure, and the FOTO measures are the only ones available.

MIPS is hard to understand, and it’s only going to get more complicated.

To few people’s surprise, MIPS is extremely complicated and pretty darn difficult to understand. We published this 5,000-word guide, hosted a 45-minute webinar, answered nearly 100 questions in our webinar FAQ, and created a MIPS participation quiz (in addition to tons of other blog content)—and we could still publish pages and pages of additional MIPS information.

And MIPS is only going to get more complicated. Right now, rehab therapists are only required to participate in the Quality and Improvement Activities categories, but there are two whole other categories (Promoting Interoperability and Cost) that therapists might have to consider in the coming years.

So, should you opt in to MIPS? That’s a question only you can answer, because you are the only one who can decide what’s right for you and your practice. That’s why it’s important to carefully weigh your personal pros and cons—and to consider the realities of MIPS participation. 

  • 2019 MIPS Quality Measures for PTs, OTs, and SLPs Image

    downloadFeb 22, 2019

    2019 MIPS Quality Measures for PTs, OTs, and SLPs

    There are boatloads of information floating around about MIPS and its requirements—and considering how complex it is , there’s little question as to why. Certain parts of the program bear the brunt of the intricate legalese, though—one of which being the Quality category. A descendent of the defunct PQRS program, the Quality category has more than 250 measures—each with unique reporting requirements. Of those measures, the final rule listed the following 11 as specifically applicable to PTs …

  • Common Questions from our Cloudy with a Chance of Reform Webinar Image

    articleFeb 13, 2017 | 13 min. read

    Common Questions from our Cloudy with a Chance of Reform Webinar

    In our first webinar of 2017 , WebPT’s co-founder and president, Heidi Jannenga, teamed up with CEO Nancy Ham to discuss the current and future healthcare trends that will impact PTs, OTs, and SLPs. (Missed it? No worries; you can view the complete recording here .) As always, we received quite a few questions during the presentation—way more than we could address live. So, we’ve put them all here, in one handy Q&A doc. Scroll through and …

  • Cloudy with a Chance of Reform: 5 Key Healthcare Forecasts for 2017 Image

    webinarJan 5, 2017

    Cloudy with a Chance of Reform: 5 Key Healthcare Forecasts for 2017

    Predicting the weather is tough—just ask any meteorologist who has called for sun on the day of a major downpour. Well, predicting the fate of the US healthcare system isn’t much easier—there’s a lot up in the air, after all. But, even without a healthcare equivalent of Doppler Radar, there are a few key trends that are sure to have a major impact on PTs, OTs, and SLPs in 2017 and beyond. And to keep your practice …

  • FAQ: Unwrapping MIPS and the Final Rule: How to Prepare for 2019 Image

    articleDec 14, 2018 | 38 min. read

    FAQ: Unwrapping MIPS and the Final Rule: How to Prepare for 2019

    Earlier this week, Heidi Jannenga, PT, DPT, ATC, WebPT President and Co-Founder, and Dianne Jewell, PT, DPT, PhD, FAPTA, WebPT Director of Clinical Practice, Outcomes, and Education, hosted an hour-long webinar that unwrapped the many layers of MIPS and the 2019 physician fee schedule. Unsurprisingly, tearing through the layers of CMS’s latest gift revealed a crush of questions—many of which our experts didn’t have time to fully address. So, we compiled the most frequently asked ones for …

  • CMS’s Final Bow: The 2019 Final Rule Image

    articleNov 5, 2018 | 8 min. read

    CMS’s Final Bow: The 2019 Final Rule

    Last week, the Centers for Medicare and Medicaid Services (CMS) published its 2019 final rule . Clocking in at just over 2,300 pages, the final rule isn't exactly a light read—especially because the legal lingo can be harder to interpret than Shakespearean verse. Luckily, we have the script—with all its twists and turns—decoded and ready for you to review. Here's the synopsis of all the physical therapy, occupational therapy, and speech-language pathology Medicare changes for 2019: Out, …

  • The 2020 Proposed Rule: Bite-Sized Edition Image

    articleAug 13, 2019 | 6 min. read

    The 2020 Proposed Rule: Bite-Sized Edition

    Too much of anything is bad for you—even if it’s something you like. Too much sun will give you some gnarly burns. Too much exercise can damage your muscles or cause stress fractures. Even too much Chipotle can make you sick (much to my eternal disappointment). All humans need to avoid consuming too much of one thing—and reading through CMS’s annual policy changes is, inarguably, way too much . So, we’re gonna keep this explanation of the …

  • Common Questions from our Regulatory Roundup Webinar Image

    articleDec 15, 2017 | 19 min. read

    Common Questions from our Regulatory Roundup Webinar

    Earlier this week, WebPT’s own Heidi Jannenga, PT, DPT, ATC/L, and Charlotte Bohnett teamed up to present a webinar detailing the most important regulatory updates that will impact PTs, OTs, and SLPs in 2018. During this hour-long session—which you can view completely free of charge here —our co-hosts covered a lot of legislative ground. And not surprisingly, they also received a lot of audience questions. While we didn’t have time to answer all of those questions live, …

  • MIPS 101 Image

    articleJul 24, 2019 | 3 min. read

    MIPS 101

    The Merit-based Incentive Payment System, or MIPS, is one tough cookie. It’s complicated and downright frustrating at times—but it’s something that rehab therapists need to be familiar with. If you’ve been looking for a no-nonsense, easy-to-follow MIPS explainer, then you’ve come to the right place! Just play the video to understand the basics behind this latest government program.  If you’ve finished the video and want a followup (or a recap) of the more complicated info we discussed, …

  • Hot Out of the Oven: Highlights of the 2017 Final Rule for PTs, OTs, and SLPs Image

    articleNov 9, 2016 | 8 min. read

    Hot Out of the Oven: Highlights of the 2017 Final Rule for PTs, OTs, and SLPs

    Halloween may be over, but if you didn’t get your fill of scares, I’ve got the perfect activity for you: reading through 1,401 pages of pure Medicare gobbledygook. Screaming yet? (Or should I check back at around page 500?) I kid, of course; there’s no need for you to slog through this year’s extra meaty Final Rule —which details the Medicare fee schedule and other important Medicare regulatory and reimbursement changes for physical therapy, occupational therapy, and …

Achieve greatness in practice with the ultimate EMR for PTs, OTs, and SLPs.