July 12th CMS MIPS Announcement – Will MIPS Help or Hurt Your Practice?  Part 3

The latest CMS communication clarifies some topics but “muddies” others.

It’s now official.  Outpatient rehab will participate in MIPS in 2019.

The July 12, 2018, CMS announcement emphasized a new topic, “Patients Over Paperwork,” with the goal of lowering documentation time by 51 hours per year, per provider.

One specific change that relates to outpatient rehab is, “Remove burdensome and overly complex functional status reporting requirements for outpatient therapy.”  We’re all familiar with the eval complexity codes.  You may not be aware that therapists are currently expected to defend eval code complexity by following a CMS workflow that separates topics into four categories, and then scores each category individually.  This is followed by 100-200 words of defensive documentation detailing each factor that impacts complexity.

While Systems 4PT recommends this defensive documentation in a 10-second workflow, every other EMR requires the therapist to manually tabulate, score, and then type the defense (10-15 minutes of work).

The APTA’s interpretation of “Patients Over Paperwork” was, “Goodbye Functional Limitation Reporting – Hello MIPS?”

This is the muddy part.

EACH OF US wants to see documentation streamlined.   WE ALL want to treat more and type less.   But we need to keep two things in mind:

  1. These topics are proposals. They may or may not happen.
  1. If these changes do happen, what workflows will replace them? Remember, MIPS is a process of scoring numerous topics.  “Quality” comprises 50% of the MIPS score.  And patient progression/outcomes comprise the majority of the “Quality” score.
    1. Like it or not, “Severity” is interwoven with progression. For example, consider two patients with a sprained ankle.  One patient is an obese, chain-smoking 78-year-old with a history of falls.  The other patient is an 18-year-old high school cheerleader. Obviously, CMS needs some mechanism to recognize the first patient is more severe than the second.  Plus, if “Severity” is not defended, what then assures anyone that MIPS progression is being fairly reported?   What stops the practice across town from reporting inflated severity to improve their MIPS score?   Our expectation: If the necessity to defend eval code severity is eliminated, CMS will either institute some new workflow, or will adjust their scoring to protect from gaming, (which would likely discriminate against patients who truly are high-severity).
    2. If we stopped reporting G-codes, how will CMS judge progression? Outcome submission via a registry could be the answer but realize:  We would be trading an old workflow for a new workflow.

Like we said, “muddy.”

The CMS announcement included two other important topics for outpatient rehab:

  1. “Advancing Virtual Care. Paying clinicians for virtual check-ins, (brief, non-face-to-face appointments via communications technology), paying clinicians for evaluation of patient-submitted photos, and expanding Medicare-covered telehealth services to include prolonged preventive services.”   The implications are obvious.  We’ll all be watching this.
  1. The announcement increases the emphasis on “Interoperability, encouraging information sharing among healthcare providers electronically, so patients can see various medical professionals according to their needs while knowing that their updated medical records will follow them through the healthcare system.” There is mention of increasing the emphasis (i.e., reward or penalty) for interoperability within MIPS.

The increased emphasis on interoperability may be the most significant news from the July 12th CMS announcement.  To succeed with MIPS, your data must be interoperable, shareable with other healthcare entities.   While Systems 4PT is ready, most EMRs are not.  You should realize that the technology/expense related to this topic will be beyond the capabilities of many EMR systems in our industry.  Practice owners who aren’t paying attention will be destined to suffer MIPS penalties, solely because of their low-tech EMR.

This Topic Deserves Attention, Right Now, Today. 

If you’re using an EMR, ask them to explain their interoperability plans.   When they answer, “interloper-what?” you need to find a new EMR right away.   If your EMR is not fluent and passionate about this topic, they’re in trouble.

If you document on paper, you are now faced with a decision:  Install a modern, capable EMR or be prepared to pay the 7%-9% MIPS penalty that is then given to compliant practices as their MIPS bonus.   Remember:  The CMS is pressuring the major commercial payers to adopt these same rules.

As discussed, MIPS is a program designed to segregate outpatient rehab into winners and losers.   Your practice is your life’s work.  These topics deserve your full attention.

Systems 4PT is in front of healthcare reform.  We are ready for MIPS with workflows that will cut your documentation time in half.  We invite you to take a look.

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