PTs and OTs are officially the MVPs!
In the CY 2024 Physician Fee Schedule Final Rule, the Center for Medicare and Medicaid Services (CMS) introduced a new MIPS Value Pathway for rehabilitation therapists, called Rehabilitation Support for Musculoskeletal Care.
Physical therapy and occupational therapy practices that take part in the Medicare Quality Payment Program are probably familiar with the Merit-Based Incentive Payment System (MIPS). But MVPs are a whole new territory—so let me be your expert guide!
With over a decade of experience in health law, privacy and compliance, I’m here to lay out your MIPS reporting options in 2024. Along the way, we’ll take a look at the differences, requirements, pros, cons, and key considerations for determining if the new MVP is right for your practice.
Traditional MIPS vs. MIPS Value Pathways (MVP) Reporting
If you’re familiar with the MIPS reporting process, you know selecting the right Quality and Improvement Activity measures can be overwhelming. In recent years, CMS has introduced an alternative: MIPS Value Pathways.
Can MVPs really solve clinicians’ reporting woes? Let’s dig into the differences between the two.
What is Traditional MIPS?
MIPS is one of the two original payment tracks for clinicians who participate in the Quality Payment Program, and requires reporting of four performance categories: Quality, Promoting Interoperability, Improvement Activities, and Cost.
Under the Traditional MIPS program, eligible clinicians have to select which Quality Measures and Improvement Activity Data they will collect and submit to CMS for the reporting period. Each requirement uses different information about health care processes, outcomes, and patient experiences of care to satisfy the MIPS “data completeness” requirements.
If it sounds complicated, that’s because it is! There are a wide range of measures to select from, but many of them do not apply to specialty practices. To demonstrate the impact of your practice while navigating the requirements of traditional MIPS can feel like a full-time job.
What are MIPS Value Pathways?
In 2023, CMS introduced MIPS Value Pathways (MVPs), an alternative to traditional MIPS, in order to simplify the reporting process.
When choosing a MIPS Value Pathway, eligible clinicians are offered a subset of measures and activities that are relevant to a specialty or medical condition. This helps participants save time and makes it easier to compare and assess clinicians who report within the same pathway.
Each MVP also includes a foundational layer of measures, which are required regardless of clinical specialty or medical condition. The foundational layer includes Promoting Interoperability measures—the same ones required under traditional MIPS—and population health measures.
MVP for Physical Therapy and Occupational Therapy
In the 2024 Physician Fee Schedule Final Rule, CMS created a new MVP relevant to physical and occupational therapists: Rehabilitation Support for Musculoskeletal Care.
Though the Final Rule brought both good and bad news for rehab therapy, the new MVP has garnered support from the field. The American Physical Therapy Association Private Practice section (APTA PPS) wrote:
“This landmark MVP is the first to allow a subset of physical therapists to meaningfully participate in the Quality Payment Program and be compared to their clinical peers.”
Rehabilitation Support for Musculoskeletal Care Quality Measures
The Rehabilitation Support for Musculoskeletal Care MVP includes 10 clinical quality measures (CQMS), seven of which use FOTO measures. The remaining three Musculoskeletal Care MVP are BMI Screening, Falls: Plan of Care, and Screening for Social Drivers of Health.
A New Cost Measure for PT and OT
The episode-based Cost measure associated with this MVP is Low Back Pain. This is a brand-new Cost measure, introduced with the input of rehabilitation therapy professional organizations like the APTA.
Shaping the Rehabilitation Support for Musculoskeletal Care MVP
It’s important to remember that regulatory guidelines change over time. While CMS updates may keep compliance professionals on our toes, they also present an opportunity for stakeholders—from clinicians to members of the general public—to provide direct feedback.
To shape the future of PT, OT, and SLP participation in the Quality Payment Program, you can submit recommendations through the MVP Maintenance Process.
What Are the Pros and Cons of Reporting MIPS Value Pathways?
With a brand-new MIPS Value Pathway option for physical therapists and occupational therapists, you might be wondering: “Should my practice participate in traditional MIPS or the Rehabilitation Support for Musculoskeletal Care MVP in 2024?”
The answer, of course, will depend on which route puts your practice in the best position to meet the MIPS performance threshold. Let’s look at some of the general pros and cons:
MIPS Value Pathways: Pros
MVPs are the future of QPP reporting for clinicians who do not participate in Alternative Payment Models (APMs). The Quality Payment Program offers several benefits of transitioning to MVPs, including:
- More meaningful groupings of measures and activities.
- Streamlined reporting requirements.
- Enhanced performance feedback.
- Getting familiar with MVPs before they become the default.
- Reducing burden across CMS programs.
MIPS Value Pathways: Cons
Of course, no system is perfect—and there’s much room for improvement when it comes to tailoring and expanding MIPS Value Pathways. Some concerns include:
- Limited scope for clinical specialties. Early feedback about “Rehabilitation Support for Musculoskeletal Care” included requests for the development of additional rehabilitation-related MVPs to include a more diverse range of services.
- Selection of quality measures. MVPs have been criticized for offering a limited pool of measures for participants to choose from, the collection of which can be costly.
- Reduced scoring potential. Some practices may perform better in measures that are not included in their chosen MVPs, or may be limited by measures that are “topped out.”
Looking Ahead at 2024 MIPS Reporting
There’s no doubt that 2024 will be a year of big changes for rehabilitation therapy—and big decisions.
Whether or not you choose traditional MIPS or MVP reporting, practices will need to account for a 3.4% cut to the conversion factor and face Promoting Interoperability requirements head-on.
To stay on top of regulatory changes and what they mean for you, I encourage you to attend our three-part webinar series on Understanding MIPS in 2024: The Impact of the 2024 Medicare Physician Fee Schedule Final Rule.
Want to know more about Raintree? Our all-in-one platform offers the only ONC-certified EHR designed specifically for rehab therapy, award-winning billing software that drives up to 40% revenue cycle improvement, and much more. Let’s start a conversation about your long-term success.
Veda Collmer, JD, CIPP/US, Raintree Systems’ General Counsel, Chief Compliance Officer, brings more than 10 years of experience in health law, privacy and compliance. Veda received the Robert Wood Johnson Foundation Public Health Law Fellowship in 2012 and completed her fellowship at the Arizona State University Sandra Day O’Connor College of Law.
