Roaring 20's are here - time to hit the ground running
Hello, roaring 20’s! This blog post is all about things to focus on to make 2020 your best year yet! There’s a lot happening in the PT and healthcare worlds at large! You can thrive!
1. Skip MIPS?
Most practices are well-versed in CMS/Medicare’s Merit-Based Incentive Payment System, also known as MIPS. In short, MIPS is a combination of new and old/updated CMS programs built on the concept of paying for value instead of for services. There are four parts to MIPS: quality (formerly PQRS), promoting interoperability (formerly meaningful use), improvement activities and cost. MIPS has been around now for several years. Physical therapists were not part of MIPS until 2019 when PT became an eligible professional type.
It’s important to note that there is no requirement, so to say, to participate in MIPS. If a physical therapist is below the low volume threshold, then skipping MIPS will not have any impact on Medicare Payments from visits in 2020. If a physical therapist exceeds the low volume threshold, then skipping MIPS will result in a penalty in 2020.
Of course, the other side of the story is you could experience a bump in payment for excellent performance in MIPS. For 2020, CMS states that the payment swing can be -9% to +9%. At first glance, it’s a huge swing, and a 9% pay bump certainly seems attractive. The reality, MIPS is required to be a budget-neutral program. This means the incentives are paid from penalties. MIPS scores are relatively high on average, and that means the incentive pool is tiny. Incentive payments have fallen well short of the promised high end of the positive side. For most practices, voluntarily participating in MIPS will not be a worthwhile endeavor.
There is much discussion about the future of healthcare payments and the idea that in time payments will shift from fee-for-service to value-based payments. There may come a time when MIPS is not optional for most PTs but that isn’t 2020. Practices should strongly assess whether the cost and time required to participate in MIPS (assuming it is optional and even if it isn’t) is worth it.
2. Pick 3 Key Performance Indicators and stick to them all year
There’s lots of discussion around Key Performance Indicators (KPIs) and which you should be looking at and which you shouldn’t. It’s certainly a discussion worth having as different KPIs can speak to different goals you may have, but it’s not a discussion that should be constant.
- Take a week to identify some interesting KPIs and then commit to a handful of them.
- Put together a list with each KPI you’ll be tracking a reason why you’ll be monitoring it (e.g., grow revenue, improve patient experience, increase referrals, etc.)
- Next, add a column to your list with specific actions you’ll be taking to maintain or enhance that KPI.
- Share this list with all of your employees to ensure that everyone is on the same page.
- Have quarterly staff meetings to see how the KPI is doing and to tweak the plan.
These will help you take your KPIs from a buzzword to an actual productivity tool for your practice in 2020.
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3. Implement a start to finish review of the patient experience at your practice
Take some time during 2020 to see your practice through the eyes of a patient. It can seem daunting trying to understand how a patient experiences your practice, but a reasonably simple analysis and tweaks can make a huge difference and pay some serious dividends.
- Start by writing a document that shows the key points in every patient’s care. Here’s a simple example
- First contact with your practice – usually a phone call
- Intake process
- First visit
- 4th visit
- Discharge process
- Add a column to your document that shows what your internal process is for each of these steps
- Add a column that shows who is responsible for what at these key intervals
You will likely find that as you write these things down and think through them that there are opportunities for improvements and enhancements that can change the way a patient interacts with your practice. Good PT software also makes a huge difference.
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4. Focus on employee development and growth
Teamwork makes the dream work as the saying goes. Your employees are one of the greatest assets your practice has. It can be hard to dedicate time to your employees due to day-to-day duties as an Owner. 2020 is a great time to refocus efforts on developing skill sets among your employees.
- Put together a list of employees
- Add a column that shows that person’s title
- Add a column that shows the person’s responsibilities. Do the title and duties align?
- Add in a column for current strengths
- Add a column showing additional responsibilities that you would like to have the person do in 2020
- Bonus points for cross-referencing this document with your KPI tracking and patient experience documents explained above
- Add in a column for pathways to realize goals such as courses, additional training, or other items
If you’re going to get serious about making headway on KPIs and patient experience, then your practice’s human resources are going to play a crucial role. Documenting where you are today and where you want to go will make a huge difference.
This document can then become a springboard to creating a professional development plan for each staff member. This can expand on the last column on pathways to goals by detailing specific steps to take and a timeline to follow.
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5. Don't forget the new modifiers for PTA and OTAs starting 1/1/2020.
No more surprises here. The new PTA/OTA modifiers start 1/1/2020. Apply modifiers to lines where the Physical Therapy Assistant (PTA) or Occupational Therapy Assistant (OTA) provides “in part.” While the modifier is required when needed starting in January, there will be no adjustment to payments for such services until 2022. This modifier is somewhat different than other modifiers. Other modifiers will give you instant feedback if a modifier is missing. With these new modifiers, you will not get any feedback if the modifier is missing other than if Medicare chooses to audit your practice. As always, one of your best defenses is proper documentation, ensuring that you can show who provided what care.
6. Be vigilant and advocate but don't make any rash changes in response to Medicare cuts until the 2021 proposed rule is released in July of 2020
While some victories were scored through advocacy on the PTA/OTA modifiers, CMS decided to move forward with the 8% cut in the 2020 final rule continuing the path towards implementing the cuts in 2021. There is no question that this is both frustrating and concerning. PT Practices have been under constant pressure with reimbursements both directly and indirectly with the churn of various programs such as PQRS, Functional Limitation Reporting (FLR), MIPS and more.
First, it’s not possible just yet to fully understand what precisely the 8% cut means. CMS is not, in theory, indicating a straight 8% cut across the board for all procedure codes. Instead, it appears to be an adjustment on some adjustment codes based on the formula that CMS uses to calculate the value of different procedure codes. One of the most significant pieces of missing information is which codes will be impacted. It could be some less often used codes, or it could be a worse scenario of workhorse procedure codes being affected. This won’t be known until the proposed rule is published, and the final rule is adopted.
The 8% cut could have significant impacts and may change the course of many practices depending on how it goes. Efforts expended in preparation should be spent on PT advocacy and on keeping your practice lean. The American Physical Therapy Association (APTA) has already stated that it will fight any and all cuts. At the end of the day, it’s power in numbers. Advocate by contacting elected officials and commenting on the proposed rule when published. Once the rule is known, then a proper analysis can be conducted.
The bottom line
2020 is shaping up to be an interesting year. There are always threats and opportunities. Staying positive and focusing on what’s important will make for a successful and profitable year! Stay tuned to our blog for more information!