Latest MIPS Data has been released
Medicare has just released its latest MIPS (Medicare Incentive Payment System) data. This data sheds light on key considerations for physical therapy practices when it comes to how to handle MIPS. Medicare tends to release MIPS data about a year or so after the close of the year. This data represents payment adjustments that providers will experience in 2020 based on 2018 MIPS performance. This is now the most recent data available.
Let's get right to the data
Straight from Medicare…
This very useful graphic to provide a lot of information all at a glance. Here are some key highlights:
What does this data mean?
As most know, MIPS is designed to be a budget neutral program overall. That means that the incentives to good performers are paid for from penalties paid by poor performers. The data shows the same trend seen in 2017, there were very few poor performers and this led to a very small incentive pool. That means that the maximum incentive anyone received was just +1.68%. This is a far cry from the potential promise of +5% for 2018. There simply weren’t enough poor performers to pay incentives. As an aside, the max positive adjustment in from performance 2017 was 1.88% so the amount has actually gotten lower.
Keep in mind the 1.68% represents the maximum payment adjustment. Only the top of the top performers received this amount. Those in the positive and positive/exceptional categories received between 0% positive and 1.68% at the top end. That means that you could have received a score putting you in the positive category and still received no incentive.
What should you do in 2020?
Every practice will have to continue to assess whether MIPS makes sense for their practice or not. It’s important to keep in mind that the Low Volume Threshold (see below) remains the same in 2020 as it did in 2020. That means that an individual provider must MEET ALL THREE of these criteria in a 1 year period, twice, to either be required to do MIPS or accept a payment reduction (negative payment adjustment)
Most PT providers fall below this threshold and given the data will likely draw the conclusion that it is not logical to participate in MIPS voluntarily. Practices with providers that exceed this threshold will need to either participate in MIPS or accept the penalties that come with skipping reporting.
Medicare is on track to raise the maximum adjustments both positive and negative in the coming years but the key is that on the positive side the adjustment is just a theoretical maximum, subject to negative adjustments adding up enough to pay for it. If the negative adjustments aren’t there (as they weren’t in 2017 and now 2018) then the maximum positive adjustment is reduced.
In addition to raising the possible adjustments, Medicare has also been steadily increasing the minimum threshold to be in the neutral category (this is called the performance threshold). That means that a practice has to do even more/better to get into that category:
2017 – 3 points
2018 – 15 points
2019 – 30 points
2020 – 45 points
2021 – Expected to go to 60
This is a double-edged sword. On the one hand, it means more providers may fail to meet this threshold creating a larger pool of money for incentive payments. One the other hand, it means that if you choose to participate in MIPS (assuming it is optional for your practice) then you must meet a higher threshold just to get to neutral, let alone the category to receive an incentive.
The future is uncertain but the past gives important data that should be used in decision making. Participating in MIPS certainly costs time and can cost money depending on method of reporting (many vendors push to sell you more stuff). Each practice will need to think about this computation when making a decision on voluntary reporting or even required reporting.
The bottom line
MIPS continues to be an important consideration for physical therapy practices but it’s key to review data as it becomes available to assess what makes sense and what the best, most prudent decision is. We are committed to continuing to blog transparently so that practices can make the best decisions possible.
Stay tuned to our blog for information as it becomes available (you can even sign up below to get our blog to your email inbox, see below).