Your Patients
  • If a patient has surgery mid-case, should this patient be disqualified from MIPS?
    • Yes. These types of cases are considered extremely medical complex and likely to make poor clinical progress based on experience and clinical judgment. To disqualify a patient, the Disqualified Checkbox should be checked on the patient's Keet account indicating they should be removed from the data registry.  Learn more here.
  • What should be done for radicular pain (i.e pain radiating from neck to shoulder)?
    • This would qualify as a medical complexity and should therefore the case should be disqualified.
  • Can seasonal patients (patients who are only residents for a short period of time) who self-discharge early in their POC be disqualified?
    • No.
  • How should we indicate those patients who will be continuing their care into 2020 and therefore should be excluded from MIPS reporting? Do we need to go back and discharge patients who are not currently active in Keet to ensure they aren't excluded from reporting?
    • For a patient to MIPS eligible in 2020, they must have started care on or after January 1, 2020 and completed care by December 31, 2020. There are two options for patients who have cases that continue into 2021:

      1. Single episode of care or case in 2020: If the patient has a case that continues into 2021 and that is the only case they were treated for in 2020, the patient can be disqualified in Keet as you normally would disqualify a patient.

      2. Multiple episodes of care or cases in 2020: If a patient has had multiple cases in 2020, the last of which continues into 2021, you will have the opportunity to disqualify that patient case on the final MIPS report that will be provided to you in mid-January. In that report, you will be able to indicate what patient cases continued into 2021 and therefore should be excluded from reporting as they aren't eligible to be reported on. This will allow you to disqualify the patient case and not all cases associated to the patient in 2020. 

  • What if the date of the MIPS qualification and the date the patient filled out the PRO form don’t match, should we update it somewhere? 
    • The MIPS qualification date must be completed within 17 days of the initial evaluation
  • How do we prompt a patient to do a PRO again other than sending a chat or telling them?
    • The automated Reminder workflow sends an email to the patients every two weeks reminding them to complete all assigned PRO forms and exercises. 
  • What happens if a patient self-discharges prior to completing a second PRO?
    • Patients who do not fill out a minimum of 2 surveys will be excluded from the denominator.
  • What patients are automatically disqualified from MIPS? 
    • Patients will be automatically excluded from MIPS participation if they are under the age of 18 years old, are not under treatment related to one of the 5 CMS-approved measures (LEFS, MDQ, NDI, KOS, QDASH) or if they do not complete 2 or more forms for an assigned measure. 
  • When should a patient be manually disqualified from MIPS participation
    • A patient may be disqualified from MIPS if the patient:
      • Is non-English speaking
      • Is unable to read
      • Has a mental impairment that compromises their understanding
      • Is determined to be extremely medical complex and likely to make poor clinical progress based on the experience and clinical judgment of the treating clinician. For example, they are being treated simultaneously for more than 1 region of injury or they have dementia, an autoimmune disease, or a metastatic disease.
  • What is the deadline to disqualify patients in Keet?
    • You can disqualify until January 10th. Any changes after that will have to be made on the final MIPS reports provided to your account the week of January 20th.
  • Are disqualified patients removed from the Failure to Progress Performance Reports?
    • Yes, patients who were identified as disqualified are removed from the Failure to Progress Performance Reports. 
  • What should I do when a patient attended their initial evaluation but never returned for a subsequent appointment yet completed an assigned PRO 2 or more times? 
    • The patient should be disqualified and a notation added into the EMR. 
  • What should I do when a patient submits a PRO form for an assigned measure after they have been discharged?
    •  If it can be documented that the final form submission was past discharge, suppress that form response (hide form) to remove it from the data.  
  • Should existing patients who I was treating in 2019 be included in MIPS?
    • No, only patients with an initial evaluation on or after January 1, 2020 should be included in MIPS.
  • Do patients that are unable to progress due to initial score being too low (false in 'can progress' column) need to be manually disqualified or are these cases automatically excluded?
    • If the patient is being seen for maintenance therapy, please check "other" on the MIPS qualification form and they will be excluded from MIPS reporting. If they are deemed medically complex, they can be disqualified. Otherwise, they SHOULD be included as its important to report on ALL patients, not just high MCID scoring patients.What should I do if a patient who was treated earlier in the year returns for a new episode of care in the same or a different area as before?
      • In this case, a MIPS Qualification form (the MIPS Qualification Clinic Form or Pre-Visit Patient Form) should be re-assigned and completed. If the patient is eligible for a MIPS PRO measure, the corresponding PRO should be assigned to the patient's account. Depending on the treatment area for the new case, the PRO may be the same or different as before. 
        The treating clinician can use their clinical judgment to exclude patients who are medically complex, who in their experience are likely to make poor clinical progress. If, as a clinician, you do not believe that a patient being treated for multiple cases is a good candidate to report on a patient reported outcome, you can choose to disqualify the patient and they will be excluded in that denominator. 
        To disqualify a patient, the Disqualified Checkbox should be checked on the patient's Keet account indicating they should be removed from the data registry.  Learn more here.


Your Providers

If a provider is no longer with our practice, should I still file for them?

  • Yes. If you are submitting as a group, any provider who treated patients for your practice in 2020 should be included in your submission.

If a provider does NOT have our entity listed under their NPI as an associated practice can we even submit their data as part of our group TIN in 2020?

  • No. All providers must have their individual NPI attached to the group NPI to be included in the group submission.

Does the MIPS bonus/penalty payment pool of providers include all providers or is it specific to specialty (PT, OT and SLP)?

  • The MIPS program payment adjustment pool is not specific to specialty - all eligible providers are included. More specifically, all MIPS eligible providers that exceed the 2020 MIPS Performance Threshold score of 45 points will be included in the bonus pool and will receive a positive fee schedule adjustment. Those providers that do not meet the 2020 MIPS Performance Threshold score of 45 points will be included in the penalty pool and will receive a negative fee schedule adjustment. This includes physicians as well as rehabilitation professionals.

Can only the supervising provider provision, complete and view a patient's PRO form(s)?

  • No, any provider that has a user profile at the same location as the patient is being treated can provision, complete, and view a patient's PRO form(s). 

Can a provider only be a part of one group submission? For example, if someone worked at two clinics during different parts of the year and both are submitting as a group is that ok?

What happens if a provider changes practices during a performance period?

  • As CMS explains, if you bill Medicare Part B charges under more than one group (TIN) during the performance period, you are required to participate in MIPS for each TIN association except in cases where those TINs are excluded under MIPS. If you start working for a new practice or create a new TIN that did not previously exist during the performance period, there is no historical performance information or final score for the new TIN/NPI. Since there is no final score, CMS will use the NPI performance for the TIN(s) the NPI was billing under during the performance period. In other words, if you work in your current practice during the performance period but then at a new practice during the payment year, CMS will use the final score for the old practice to apply the MIPS payment adjustment for the NPI in the new practice. If you are billed under more than one TIN during the performance period, and start working in a new practice or create a new TIN, CMS will take the highest final score associated with your NPI in the performance year. 

Should I opt in as an individual or a group?

  • If there are providers in your group, such as Speech Language Pathologists, who do not treat conditions that are measured by the available patient reported outcomes surveys you should report as individuals. CMS has stated that you will be able to choose whether to report as a group of individual after seeing which method is advantageous. Please find more information at the Quality Payment Program website: https://qpp.cms.gov/mips/individual-or-group-participation. You can find additional details here as well.
    Note: If you choose to submit data individually, you are required to submit at least 20 cases per measure to qualify for performance measure scoring.

How is primary therapist identified for each patient in Keet?

  • If you have an established EMR integration with Keet, Keet will automatically assign a Primary Therapist based on who conducted the Initial Evaluation. If that logic is incorrect, the Primary Therapist can be identified manually on the patients account in Keet. The system only allows you to choose one Primary Therapist for the patient, so if there is a scenario where they are seen for two episodes of care with different Primary Therapists, this can be edited on the final MIPS report provided at the end of the year. This cannot be updated in the system. 

One of our Providers is now credentialed with Medicare, but wasn't when the patient was seen, which required a co-signature. Do we need to change the NPI to the treating Provider since Medicare backdates the effective date?

  • We recommend you change the NPI to the newly credentialed Provider up to the Medicare effective date. You should leave the Supervising Therapist as the Provider that co-signed for any patients treated prior to the Medicare effective date.


General Questions

What is the 2020 MIPS Data Submission Process?

What is the error rate that is reportable, but not actionable?

  • A rate <3%

How is the PRO score change calculated? 

  • The score change is determined by subtracting the score of the first form collected from the score of the last form collected for an assigned PRO. This score is evaluated against the corresponding PROs Minimal Clinically Important Difference (MCID).

What happens if I don't begin collecting patient reported outcomes in January?

  • Medicare expects reporting on quality measure for the entire year and requires that you report on 70% of all eligible patients for each measure. The longer you wait to begin reporting, the less chance you have of reporting successfully.

When is the risk adjustment applied?

  •  Risk Adjustment will be applied at the end of the year before final reports are distributed.