THE BASICS

In 2015 Congress created MACRA which begat Quality Payment Programs (QPP) which begat the Physician Quality Reporting System (PQRS) which ultimately begat the Merit Based Payment Systems (MIPS).

Silly acronyms aside, what’s important about MIPS is that it changes the way many clinicians are paid for services. Initially, the program covered physicians and some other practitioners but not psychologists. Now Medicare has included psychologists.

AM I ELIGIBLE?

As of 2019 psychologists who serve Medicare patients have been added to the program. (Given that the program is likely to expand and be adopted by other payers, it is something that ought to be on the radar of any behavioral clinician.)

Close to 15,000 psychologists bill Medicare for services. But only 5% (well over 700 psychologists) will have to report or suffer penalties.

Psychologists are off the hook if they, 1) bill for 200 or less medicare patients/year; 2) bill for less 200 or less services/year; and 3) bill less than $90,000/year.

Low volume practitioners may opt-in, however.

DOES IT MATTER?

Yes. For two reasons. 1. MIPS reporting can have a serious impact on revenue. Based on data they report, psychologists will be subject to payment adjustments ranging from a 7% bonus to a 7% penalty beginning in 2021.

Also, 2. MIPS performance has the potential to affect a clinician’s reputation. Scores will be publicly available and will be posted to the Physician Compare website.

WHAT DO I HAVE TO DO?

MIPS scores for psychologists are based on:

  1. Quality
  2. Improvement Activities
  3. Cost

A fourth category, interoperability, is used for other participants, including psychiatrists and psychiatric nurse practitioners, but will not be used for psychologist reporters because they were excluded from the meaningful use incentives.

The formula is heavily weighted toward quality measures. An example of a quality measure would be assessing for suicide in patients with Major Depression with appropriate documentation. Another example would be assessing cognition with patient’s carrying a diagnosis of dementia.

Improvement activities can include such things as providing teletherapy services, sending clinical reports to referring physicians and the like.

Cost data is collected by CMS via claims.

WHAT IS THE EASIEST AND CHEAPEST WAY TO DO MIPS REPORTING?

Reporting can be done through a MIPs registry or a Clinical Data registry. However, they cost money and require manual data entry. MIPs can also be submitted via claims using special codes. CMS is phasing out claims reporting but it will be available in 2019.

Finally, psychologists can report through an ONC certified EHR. CarePaths is completing a module that will allow MIPS reporting in 2019. There will be no additional charge for this feature.