On April 27, 2016, CMS released the proposed rule for the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The proposed rule outlines the strategy for Merit-Based Incentive Payment System (MIPS) and Alternative Payment Models (APMs). The proposed rule strives to support a physician payment system that would continue the move away from fee-for-service payments to performance and quality. Under the proposed MIPS rule, the focus will be quality, performance and outcomes (i.e. improved safety, care coordination, and patient engagement). In addition, cost and resource utilization will be measured as well as use of certified electronic health records (EHR) technology that emphasizes more efficient information exchange and interoperability.
How will MIPS work?
As part of the proposed rule, MIPS would consolidate components of three existing programs: the Physician Quality Reporting System (PQRS), the Value Modifier (VM), and the Medicare EHR incentive program for eligible professionals (Meaningful Use). The rule also proposes that the MIPS performance period consist of one calendar year (Jan. 1 through Dec. 31), starting on Jan. 1, 2017, to serve as the performance period for payment adjustments in 2019.
Now, what does this all mean for OT/PT/SLP providers? Section 1848(q)(1)(C) of MACRA defines MIPS-eligible professionals (EP), for the first two years for which the MIPS applies to payment, as only physicians, physician assistants (PA), nurse practitioners (NP), clinical nurse specialists (CNS), certified registered nurse anesthetists (CRNA), and groups that include such professionals. Beginning with the third year of the program, 2019, and for succeeding years, the statute gives the secretary discretion to specify additional EPs, as that term is defined in section 1848(k)(3)(B) of the Act, which could include occupational therapists, physical therapists, qualified speech-language pathologists, or qualified audiologists, among other professionals.
Don’t wait to get educated
This does not mean we can all sit back and wait until 2019. If you are an OP provider and collecting PQRS today, you must continue to do so. Even if/when a changeover would occur, MIPS relies largely on the performance measurements within PQRS, MU, and the VM. The most prudent thing to do now is to continue to improve and understand how these current programs are managed. In addition, it will become increasingly important to understand the current MIPS proposed legislation and stay tuned in to the MIPS final rule. It is also recommended that you familiarize yourselves with how your national organizations—American Occupational Therapy Association (AOTA), American Physical Therapy Association (APTA), and American Speech-Language-Hearing Association (ASHA)—are preparing their members on how MIPS will impact your practice. How Medicare providers will get reimbursed and the rules around outcome performance measurement and reporting will certainly change what we do, but with a proactive strategy, it is possible to incorporate current efforts and resource investments to help optimize the MIPS process when it does hit the rehabilitation therapy world.
Learn more about MACRA and MIPS here.
Comments and feedback on the rule are due to CMS by June 27, 2016. Refer to file code CMS-5517-P COMMENTS. Follow the “Submit a comment” instructions.