Changes in store in year two
This year was the first that occupational therapists who bill outpatient Medicare Part B were included in the Quality Payment Program (QPP) under the Merit-based Incentive Payment System (MIPS). Occupational therapists will continue to report in two MIPS categories: quality, and performance improvement.
CMS made some changes to the MIPS program for calendar year 2020. The 2019 performance threshold to receive a positive adjustment was 30 points, but in 2020 it is being raised to 45. Similarly, the exceptional performance threshold has been raised to 85 points.
Occupational therapists continue to be exempt from reporting on promoting interoperability (EHR measures). Although additional cost measures were approved for 2020, at this time none of them apply to occupational therapy. These exemptions reweigh the other categories so that quality is worth 85% and performance improvement is worth 15% of the total score. The potential payment adjustment for reporting year 2020 is up to 9% from 7% in 2019.
The quality measures set has been updated. Two quality measures are being deleted from the Physical Therapy/Occupational Therapy Specialty List:
- Measure #131, Pain Assessment and Follow Up
- Measure #223, Functional Status Change for Patients With General Orthopedic Impairments
The remaining measures are now all listed in the specialty set. Quality measures must meet at least 70% of data completeness in 2020.
In the performance improvement category, CMS is updating the group reporting requirement. Previously, only one practitioner had to perform the activity to get credit. In 2020, CMS is increasing the participation threshold for group reporting to 50% of the clinicians in the practice. The group must perform the same activity, but it does not have to be done concurrently as long as it is during any continuous 90-day period within the same performance year. Two new Improvement Activities were added, 7 were modified, and 15 were removed.