The Merit-Based Incentive Payment System (MIPS) has been around since 2017, but it has undergone no shortage of changes during that time—making compliance an uphill battle for many private practices. Even for the bigger corporate PT fish, staying updated without a MIPS champion on staff is no easy feat. That’s why having a Qualified Clinical Data Registry (QCDR) for MIPS participation is so important for today’s practices to stay successful.
What is a QCDR for MIPS?
QCDRs are CMS-approved vendors whose primary directive is to improve health care quality and delivery. In short, they work to make MIPS participants' lives easier. Defined by CMS as “a CMS-approved entity that demonstrates clinical expertise in medicine and quality measurement development,” a QCDR will collect data from treating providers and submit it to CMS on behalf of those providers for the purpose of improving the quality of care for patients.
What will a QCDR do for your rehab therapy practice?
If you’re going to partner with a QCDR, you need to understand the benefits before jumping in. With that in mind, here are a few reasons you should adopt a QCDR in your rehab therapy practice.
1. It’s an all-in-one MIPS reporting solution.
Staying in the know about all the yearly changes that occur with the MIPS program is a necessity for MIPS participants looking to get the maximum positive payment adjustment—or hoping to avoid a negative one. But to do this, providers would have to take time away from patient care to sift through the endless pages of MIPS rules and regulations. Luckily, using a QCDR is akin to pressing the MIPS “easy button.” All you need to do is select and submit the data you wish to report on, select your reporting type, and verify the number of MIPS-eligible clinicians you have under the same tax ID number (if you’re reporting as a group)—and voila, the QCDR takes care of the rest of the MIPS processes. Even better, a QCDR will improve efficiencies for your clinic, leading to cost savings and improved payments.
2. A QCDR provides reporting measures specific to rehab therapy.
Possibly the biggest reason for rehab therapists to use a QCDR is that it simplifies reporting for quality measures and improvement activities—the two MIPS measures applicable to PTs. One pain point for rehab therapists is that the current MIPS quality measure set is devoid of commonly-used patient-reported outcome measures (PROMs) like:
- the lower extremity functional scale (LEFS),
- the neck disability index (NDI),
- the modified Oswestry disability index (ODI),
- the quickDASH (disability of the arm, shoulder, and hand),
- and many other PROMs.
A QCDR provides a workaround for this by offering what are instead called QCDR measures that include the PROMS rehab therapists use in practice. And QCDR measures are CMS-approved for MIPS participation and reporting. For example, the Keet Outcomes QCDR uses IROMS measures to report for MIPS.
3. QCDRs offer collaboration to assist your practice.
At a minimum, QCDRs must communicate quarterly with the providers they are representing. This affords providers and the QCDR an opportunity to improve quality of care and make other improvements where necessary. Additionally, QCDRs regularly undergo harmonization with other QCDRs and between quality and process measures to provide “clinicians with a larger cohort for comparison for performance scoring and benchmarking” in the MIPS program.
4. QCDRs provide data and reporting capabilities for more than just MIPS.
The utility of a QCDR stemmed from the MIPS program, but it has grown beyond just MIPS. The data collection and reporting metrics utilized by QCDRs make them an opportune platform to participate in other value-based care (VBC) programs. And it’s not just CMS considering the expanded role of QCDRs in VBC; in one example, participation in a QCDR was a criterion for this group of 235 urologists with over 24,000 patients in a Blue Cross Blue Shield of Michigan VBC program launched in 2012. VBC is here to stay and is very likely the payment model of the near future. As such, QCDRs will be an invaluable tool for rehab therapists just as soon.
How can a QCDR help practices in the future?
With traditional MIPS set to sunset in coming years in favor of MIPS Value Pathways (MVP), QCDRs can assist in this transition and provide needed insight and guidance as reporting and data collection standards change over time. And while an MVP specific to rehab therapy does not exist currently, there is a Musculoskeletal (MSK) Care and Rehabilitation Support MVP introduced for possible inclusion in the 2024 performance year.
Likely to be further divulged in the 2024 final rule proposal—released later this year—the MSK MVP will include 14 Quality Measures (including five IROMS measures) and 11 Improvement Activities—five high-weighted, five medium-weighted, and one activity for the “Implementation of Patient-Centered Medical Home model.” For a full document with more details on this proposed MVP check out the download on the Quality Payment Program website.
Compliance and billing are often likened to the ugly ducklings of running any healthcare business, and rehab therapy clinics are no different. When given proper attention and investment, compliance and billing provide golden eggs for reimbursement and healthy business practices. Using a QCDR is one way to invest in these processes so you can spend less time with burdensome administrative tasks and more time treating patients.