Earlier this year, we shared Medicare's MIPS (Medicare Incentive Payment System) data from 2018. You can read more about that by click here. At the time, that was the most recent data that Medicare had to share. As most folks know, there is a lag in the data and in the payment adjustments that Medicare applies. For example, for those participating, MIPS performance in 2020 will result in a payment adjustment in 2022.Medicare has now released a snapshot of 2019 data. This data now represents the latest data available. The data has changed slightly but the overall picture really remains the same. This data is crucial for so many physical therapists because many so many PTs fall below the low volume threshold for MIPS. That means that there is no obligation to participate in MIPS and that participating in MIPS can actually open the door to a negative payment adjustment with, as the data shows, little potential upside. Of course, there is no hard and fast rule for any provider or practice but it's imperative to take a look at the data to see what it's telling us.
This is graphic taken directly from Medicare. The data is from 2019 participation in MIPS:
The data more or less tells the overall story of MIPS which is that there have been few poor performers. In addition, there have been many, many exceptional performers. If this were an exam and needed to be scaled, it would need to be scaled. The bottom line is pretty straight forward - with absolutely no poor performers there is simply no money from that source to pay out exceptional performers. The only monies available to pay exceptional performers are from some relatively small appropriations made by Congress. That money results in a pretty small positive performance adjustment to be spread out across a lot of exceptional performers. Being in the positive category didn't earn one any actual positive performance adjustment. Let's distill it down further:
It's impossible to create a single blanket rule but trends and data do matter. Most providers will continue to fall below the Low Volume Threshold in 2021. Medicare has already stated that it will keep the LVT the same for 2021 based on the proposed rule (which likely will not change when the final rule is passed).The low volume threshold 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)
Medicare will continue to adjust its maximum incentive and maximum penalty. Medicare started with a swing of supposedly -5% to +5% and that was ramping up to +/- 7% and then more. The are just maximums and the way the program is structured is such as the performance across all providers ultimately dictates the final adjustments. This and prior data show that these maximums basically just exist on paper and are theoretical, at least at this point. The above information can apply to any MIPS year but there is one other aspect here and that is COVID-19's impact on MIPS. A few month's ago, Medicare announced that they were basically going to waive the 2020 performance year. While the 2020 year will not impact payments until 2022, it remains to be seen if they will carry this policy forward into 2021. Keep in mind that the data above is from reporting data in 2019 before COVID even hit. Combining these two things should also be a part of the discussion at your practice.
MIPS has now been around for several years across the healthcare and now in the PT world and that has allowed for starting to see some trends. Those trends show fairly stable patterns of nearly universal high achievement and, as it follows, low incentive for participation. It's not possible to know with certainly where MIPS goes next but the data speaks for itself and you should use it to help determine what to do in 2021 if you, like most PTs, are not required to participate in the program.
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