The Centers for Medicare and Medicaid Services (CMS) has expanded eligible clinician types to include clinical psychologists for 2019 reporting to the Merit-based Incentive Payment System (MIPS). Under MIPS, Eligible clinicians may earn performance-based adjustments based on measure and activity data aimed at improving quality of care and services to patients. Other non-physician practitioners now required to report include physical therapists, occupational therapists, speech-language pathologists, audiologists, and dietitians.
Impact on 2021 Medicare Part B Payments
The MIPS program impacts Medicare Part B payments for physician services covered by the Medicare Physician Fee Schedule, including payments to psychiatrists for seeing patients in Federally Qualified Health Centers and Rural Health Clinics – as long as those payments are separate from the federal bundled payment. Clinical psychologists who “opt out” of Medicare and are paid directly by Medicare beneficiaries under private contract are not included in MIPS.
2019 MIPS reporting will impact 2021 payments. Each eligible clinician or group that participates in MIPS will receive a composite score based on four performance categories and weighted as follows:
Scores are then compared to a “performance threshold” based on the median performance of all eligible clinicians from a prior period. For 2019, the performance threshold is 30 points and will impact 2021 payments as follows:
Exemptions and Opting-In
Psychiatrists, and other non-physician practitioners, will be exempt from MIPS reporting requirements and payment adjustments for falling below a low-volume threshold. Specifically, clinicians are exempt from reporting if they are meeting one of the following exemptions:
- Bill $90,000 or less in Medicare Part B allowed charges for covered professional services payable under the Physician Fee Schedule (PFS), or
- Provide covered professional services for 200 or fewer Part B-enrolled individuals, or
- Provide 200 or fewer covered professional services to Part B-enrolled individuals
New for 2019 reporting is the option of opting-in to MIPS if a clinician or group is exempt, but exceeds 1 or 2 of the low-volume threshold criteria.
CMS estimates that 91.2% of clinicians and groups that participate in 2019 MIPS reporting are expected to receive positive or neutral payment adjustments. For 2017 reporting, 71% of participants actually earned both a positive payment adjustment and an additional bonus for exceptional performance.
With these kind of metrics in mind, exempt clinical psychologists, and others, may find it beneficial to opt-in to the program. For 2019 reporting, for a practice that bills $500,000 in Medicare each year, this could determine a payment of more than $535,000 in 2021. Opting-In to the program allows for opportunity to strive for this type of bonus money.
2019 Reporting Options
Requirements for 2019 reporting for each category are as follows:
Clinical psychologists, therefore, will only be responsible for submitting data to the Quality Category and attesting to Improvement Activities. With re-weighting, the Quality Category will count for 70% of the final MIPS score.
CMS has a measure-set of 25 Mental/Behavioral Health measures that clinical psychologists can select from. Additionally, choosing to report through a Qualified Clinical Data Registry, such as the American Psychology Association’s PsychPRO Registry, allows for reporting on additional measures beyond what is housed through CMS. QCDRs also allow for attestation of Improvement Activities and expand the number of available activities to select from, potentially leading to higher MIPS scores and higher bonuses.
Quality measure and Improvement Activity selections should meet the needs of your unique practice and workflow. The Encompass Clinical Quality Management team is skilled in analyzing your current data collection system, finding the right solution if you do not have one in place, and equipping you with a reporting strategy to set you up for MIPS bonus potential. In fact, for the 2017 MIPS reporting year, our quality clients achieved positive payment adjustments and exceptional performance bonus payments for 2019 payments ranging from $334,000 to $580,000.
Reimbursement penalties for lack of participation in federal reporting programs are rapidly increasing. Additionally, provider and practice reputations are at risk as CMS continues to release quality metric performance ratings to the public via its Physician Compare website. While there is much to lose in non-participation, there is also a lot of potential revenue up for grabs. Our team is ready to help pave your way.