MIPS has fully replaced FLR and FLR no longer needs to be completed and may result in claim rejection.

Basic knowledge of MIPS? 

1. There is no benefit nor penalties to reporting if you are not eligible. However therapists will not be given a raise in the participations benefit year (2 years from participation year) if they do not participate.
2. Practices may report as individual providers or as a group at the individuals/practices discretion.
3. Reporting will be separate if there are multiple tax ids. A physician visiting 2 facilities and filing under 2 tax ids will have to run the calculations for themselves separately for each tax id.
4. To be eligible, the physician or group must meet certain minimum requirements that change year over year. Use the QPP Participation Lookuptool to see the threshold for your year of interest. The thresholds are usually based on:
   1. Exceed certain number of dollars in Medicare allowed charges.
   2. Exceed certain number of  Medicare patients.
   3. Exceed certain number of covered services.
5. A provider or group who meets 1 but not all requirements may opt-in to participation.
6. A provider who is not participating may "volunteer" data. They will receive no incentives nor penalties but will receive feedback for future reporting.
7. A provider may check their individual eligibility at: QPP Participation Lookup
8. A provider who wants to participate but does not meet the requirements as an individual or group may join a "virtual group" to allow multiple TIN's to be combined. CMS must be contacted directly for this. See the eligibility link above to find their contact information.

How is MIPS done in QuickEMR?
MIPS allows both claim and outcomes based reporting. Any system may use claims based reporting by generating the appropriate charge codes, however their is a stiff penalty for doing MIPS exclusively as claims based as the outcomes based measures may not be included. To add outcomes based measures (1 is required per patient) a software must become a certified registry. QuickEMR (and all known therapy targeted EMRs) does not meet the requirements to be a QCDR. So QuickEMR has partnered with several 3rd party Certified Registries. QuickEMR currently supports integration with 

• FOTO Inc (https://www.fotoinc.com/) To sign up now or learn more about FOTO Outcomes and MIPS Registry contact Judy Holder at JudyHolder@fotoinc.com and let her know you are with QuickEMR. FOTO will collect the necessary data through the integration and report it directly to CMS for you.
• APTA - contact their sub-contractor at FigMD (kellinl@figmd.com) for more information.
• Health eFilings - contact clientservices@healthefilings.com for more information.
• Other may be possible upon request. Contact support@quickemr.com or use the "help" widget within QuickEMR.

What will I have to do for MIPS?

Summary: 6 discipline specific measure must be generated and sent to cms.gov and the practice must participate in several approved improvement activities and report the participation in a brief survey at the end of the year. It may not be possible for a PT/OT/ST provider to complete 6 measures due to limited reporting options.

Quality Measures: PT/OT/ST providers that are eligible will be required to fill out 6 Quality Measures for each patient. If participating in MIPS these measures must be reported for all patients even if they are not under Medicare insurance. This is the most important category and will be a majority of the "score" for PT/OT/ST.  These measures details can be found here: https://goo.gl/sTP8To. Several methods exist for generating these measures including manual creation by the provider, automatically generating this information from patient outcomes data such as entry and exit surveys, you must complete each measure for over 60% of your patients, regardless of their payer, in order to receive max points.

Improvement Activities: Providers must declare that they participated in 1-4 improvement activities in the Improvement Activities list found https://goo.gl/xPzejs for at least 90 days (some activities specifically require longer). The number of activities required will change based on the size of the practice. Less than 15 providers will have 1 high weight or 2 medium weighted activities while 15 or greater must submit 4 medium or 2 high weighted improvement activities. When the participation is complete the provider will visit cms.gov, and select the activity and date ranges. Most of these activities involve improved patient and provider education on high risk behaviors such as drug, alcohol, and tobacco education or improved therapeutic methods and patient communication.

Promoting Interoperability: PT/OT/ST providers are not required to participate in this category at this time (last reviewed in 2021). If or when participation is required the providers must answer a brief survey at the end of the year stating they communicated appropriately with and educated their patients. Those measures can be found here: https://goo.gl/NsLstj

Cost: Cost is not reported by the provider. It is an internal calculation done by Medicare to determine the total cost of a patient and how it relates to a national average for similar care. It does not affect PT/OT/ST at this time.

What does this reporting do?

The results of your reporting will generate a score from 0-100. The score will then be placed on a curve with all Medicare providers. The highest scores on the curve will result in up to 7.5% increase in payout while the lowest scores will result in a 7% decrease in payments. Medicare has set minimum point values to prevent a pay penalty in the past and may continue to do so. It is likely that a provider who participates in a registry and completes their improvement activities will not receive a pay decrease. However it is also unlikely, due to the limited measure options for therapy, that a pay increase will be given.