As therapists in a changing healthcare climate, we are often trying to figure out where Medicare might be headed and how it affects us. One of the best ways to determine this is to look at the Medicare Payment Advisory Commission (MedPAC), a nonpartisan agency that provides Congress with analysis and policy advice on Medicare.
MedPAC’s mandate is to analyze access to care, quality of care, and other issues affecting Medicare. The ultimate goal of implementing and tracking quality measures is to improve outcomes in healthcare.
Two ways in which MedPAC’s recommendations can impact healthcare professionals are as follows:
- Outcomes reporting – becoming familiar with what measures are required and how to report on those measures
- Reimbursement – as MedPAC’s recommendations will likely impact reimbursement systems and/or levels of reimbursement.
This is why it is important to know what the MedPAC reports are stating.
Though Congress is not bound to take MedPAC’s recommendations, it often does. For example, MedPAC noted a few years back that Medicare doesn’t know what benefit patients are receiving from therapy, while therapy costs have continued to increase by 10% or more per year. This resulted in the current collection of data known as Functional Limitation Reporting (G codes and severity modifiers) for outpatient therapy.
One initiative we’re focused on is the Merit-based Incentive Payment System (MIPS). In March 2018, MedPAC released a report titled “Moving beyond the Merit-based Incentive Payment System.” MIPS is part of the Quality Payment Program created by the Medicare Access and CHIP Reauthorization Act of 2015.
In the March 2018 report, MedPAC makes the following recommendations to congress:
- Eliminate the current Merit-based Incentive Payment System
- Establish a new voluntary value program in fee-for-service Medicare in which:
Clinicians can elect to be measured as part of a voluntary group
Clinicians in voluntary groups can qualify for a value payment based on their group’s performance on a set of population-based measures
Recently, staff from the American Physical Therapy Association and a group of non-physician providers currently excluded from MIPS met with staff at the Center for Medicare & Medicaid Services. Concerns and recommendations related to low-volume thresholds, certified electronic health records, weighting of MIPS categories and alternative payment models options for non-physician providers were shared.
At the MedPAC April 2018 meeting, uniform outcome measures in post-acute care across all settings were discussed and include:
- Hospital readmission rates
- Medicare spending per beneficiary
MedPAC recently released their June 2018 report to Congress. Many topics discussed at the April meeting were included in the June report, and there is more to be learned about the PAC setting uniform outcome measures.
As one might expect with all recommendations, the “devil is in the details.” Providers will be concerned with administrative burdens and impacts on operational functions. In general, professionals agree with improving outcomes and our professional associations support this too.
As therapy professionals, we’ll continue to monitor the latest initiative of comparing performance measures across PAC settings. For readers, I suggest asking questions such as the following:
- What are we doing to minimize hospital readmissions?
- How are we making sure that there is a smooth and successful transition to the next level of care?
- At each level of care, is the patient receiving all necessary services at the appropriate intensity levels?
Based on the recently released Medicare Physician Fee Schedule proposed rule for 2019, there’s a strong possibility that privately practicing physical and occupational therapists and other non-physician providers will have to participate in MIPS in 2019. Therefore, accessing your professional association and CMS resources on this topic is worthwhile.
MIPS requires reporting in four performance categories—quality, promoting interoperability, clinical improvement activities and cost. Providers earn points in each category, producing a total annual MIPS score, which in turn determines whether the providers earn a payment incentive, remain neutral in payment, or are subject to a penalty.
Several data points must be reported electronically through certified electronic health record vendors or registries. CMS is expected to make its decision on the inclusion of non-physician providers in MIPS in early July 2018.
In an ideal scene, when MedPAC’s recommendations are carried out we should expect more efficient delivery of healthcare services and better patient outcomes in the areas that are tracked. Of course, process improvement must be part of the system and therefore, administrative burdens should be assessed and improved.
In the recently released June 2018 MedPAC report, chapter 3, CMS proposes updates within the physician fee schedule that will contribute to increases in EM (Evaluation and Management) at the expense of non-ambulatory EM services. One example of the proposed decrease includes physical therapy by 3.8%. The American Physical Therapy Association will be commenting on this proposal.
Of interest to the skilled nursing industry is MedPAC’s comments in a June 2018 comment letter to CMS regarding SNF reimbursement and quality reporting for FY 2019 and 2020. This includes supporting a reduction in payment updates to any provider not supplying quality data while not supporting reimbursement for quality reporting. The comment letter can be accessed here.
Currently, MedPAC commissioners include various professionals including physicians, nurses, attorneys, pharmacist, and policy experts. We think it’s important to bring in therapy professionals who meet the criteria of becoming a commissioner and can represent the impact of MedPAC ideas and recommendations on the therapy world and patients. We hope that after reading this post, you agree.
Kristy Brown, MS, CCC-SLP has more than 25 years of management experience as CEO/ President of Centrex Rehab and former executive director at Augustana Therapy Services. Clinical Physical Therapy Specialist Matthew Mesibov, PT, GCS is responsible for providing clinical support to the physical therapists and physical therapy assistants at Centrex Rehab.