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MIPS Reporting in 2024: Resource Center for Rehab Therapists​

Top questions from PT, OT, SLP, and rehab therapy, answered by the compliance experts here at Raintree.

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Your Guides to MIPS Reporting

Whether it’s your first time or you’re a MIPS pro, reporting to the Centers for Medicare and Medicaid (CMS) can be, well… complicated. But it’s important to maximize your MIPS score to increase the chance of a positive payment adjustment—and avoid penalties!

Every year, our compliance experts answer questions from our therapy and rehab community about updates and changes in the regulatory environment. We’ve compiled some key information here to serve as your MIPS Reporting Resource Center.

Dive in for MIPS success in 2024!

FEATURED
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CMS Promoting Interoperability: A Primer for Reporting in 2024

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Is the new MIPS Value Pathway for MSK right for your rehab therapy practice? Let's take a look at the pros, cons, and key considerations.
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CMS Calendar Year (CY) 2024 Physician Fee Schedule Final Rule Summary

Calendar Year (CY) 2024 Physician Fee Schedule Final Rule was published in November 2023. Dig into Medicare updates for rehabilitation therapy.
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MIPS Lexicon: Important Terms and Acronyms to Understand (Before Reporting!)

This MIPS lexicon is here help you navigate the regulatory landscape and set your practice up for success when it's time to report!
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Understanding MIPS Hardship Exceptions for Rehab Therapy

Explore the requirements, historic trends, and 2024 outlook for MIPS hardship exceptions with Veda Collmer, JD, CIPP/US.
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WATCH

MIPS 2024 Webinars

Deep-dive sessions now available on demand. Stay tuned for future events!

FAQS

Intro to the Merit-Based Incentive Payment System

Start here to cover the basics.

The Merit-Based Incentive Payment System (MIPS) is one way to participate in the Quality Payment Program (QPP), a program authorized by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The program rewards MIPS eligible clinicians for providing high quality care to their patients by reimbursing Medicare Part B-covered professional services.

Quality, Promoting Interoperability, Improvement Activities, and Cost.

The defined Performance Period is the annual calendar year for data collection (i.e. Jan 1 2023-December 31 2023).

The reporting period is defined as January 1 - March 31 of the year following the defined Performance Period (i.e. Jan. 1, 2024 - Mar. 31, 2024 is the reporting period for the 2023 performance period).

Participation and Eligibility

Where to learn more about your MIPS eligibility and participation options.

To be eligible for MIPS, you must:

  • Be a MIPS-eligible clinician type;
  • Exceed the low-volume threshold as an individual or group; and
  • Not be otherwise excluded because of your Medicare enrollment date or your status as a Qualifying APM Participant (QP), or as a Partial QP that has elected not to participate.

 

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MIPS Eligible Clinician Types

Low-Volume Threshold

Other Exclusions

  • Physician (including doctor of medicine, osteopathy, dental surgery, dental medicine, podiatric medicine, and optometry)

  • Osteopathic practitioner

  • Chiropractor

  • Physician assistant

  • Nurse practitioner

  • Clinical nurse specialist

  • Certified registered nurse anesthetist

  • Physical therapist

  • Occupational therapist

  • Clinical psychologist

  • Qualified speech-language pathologist 

  • Qualified audiologist

  • Registered dietitian or nutrition professional

  • Clinical social worker

  • Certified nurse-midwife

You exceed the low-volume threshold and are a MIPS eligible clinician if you: 

  • Bill more than $90,000 in allowed charges for Medicare Part B covered professional services AND 

  • Provide covered services to more than 200 Medicare Part B patients AND 

  • Provide more than 200 covered professional services to Medicare Part B patients. 

CMS will evaluate individuals and groups on the low-volume threshold. 

 

CMS is continuing the policy that allows clinicians and groups that meet or exceed 1 or 2 of these thresholds to opt-in to MIPS eligibility and participation. 

You’re excluded from MIPS in 2024 if you:

  • Enrolled as a Medicare provider on or after January 1, 2024.

  • Are identified as a Qualifying APM Participant (QP) or as a Partial QP that has elected not to participate. (This information is added to the QPP Participation Status lookup tool, and is tentatively scheduled for July, September, and December 2024.)

Clinicians can can check their eligibility using the QPP Participation Status lookup tool. You will need to enter each eligible clinician’s NPI to check status. Please keep in mind that eligibility is defined at the TIN-NPI combination level, and a clinician must exceed low-volume thresholds to be required to report MIPS.

Yes! The MIPS program has always had an opt-in opportunity. This is key for clinicians that perform really well in MIPS performance categories and want to submit data to CMS and earn a potential positive incentive. Learn more on the QPP resource page about MIPS eligibility.

No. Clinicians can register as a subgroup to report a MIPS Value Pathway (MVP), but subgroup participation isn’t an option for traditional MIPS.

MIPS Scoring and Payment Adjustments

Discover how your MIPS score affects future Medicare payments.

The performance threshold is the number against which your final score is compared to determine your payment adjustment. The performance threshold for the 2024 performance year remains 75 points. See the table below for more information about the relationship between 2024 final scores and 2026 payment adjustments. 

 

2024 Final Score

Payment Impact for MIPS Eligible Clinicians for the 2026 MIPS Payment Year

0.00-18.75 points

-9% payment adjustment

18.76-74.99 points

Negative payment adjustment (between -9% and 0%)

75.00 points (perf threshold=75.00 pts)

Neutral payment adjustment (0%)

75.01-100.00 points

Positive payment adjustment (scaling factor applied to meet statutory budget neutrality requirements) 

As a reminder, the 2022 performance year (2024 payment year) was the last year for the additional positive payment adjustment for exceptional performance.

The maximum negative payment adjustment for the 2022 payment year (2020 performance year) and beyond is -9%. The actual payment adjustment (positive, neutral or negative) a client will receive for the 2026 MIPS payment year will be based on their MIPS final score from the 2024 performance period and may be subject to a scaling factor to ensure budget neutrality, as required by the Physician Fee Schedule.

LEARN

How Could MIPS Payment Adjustments Affect the Future of My Practice?

Meeting the MIPS performance threshold will determine your payment adjustment in 2026.

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Raintree Systems is a leading provider of software for PT, OT, SLP, ABA and multi-specialty practices. Our all-in-one platform includes the only certified EHR designed specifically for rehab therapy.

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