2019 MIPS Draft Reports FAQs

  • On every Therapist's patient info summary report there are patients that have surpassed the MCID and are still labeled on the data sheet as "f" in the "progressed" column. Is this an error on the back end?
    • For the NDI, MDQ, Quick DASH, and the pain scale, better function is indicated by a lower score meaning you want to see a negative score change. For example, the pain scale has an MCID of 2. For a patient to have progressed, the score change would need to be -2 or greater (up to -10).

  • On the Compliance Report, some Therapists are listed twice. Is this because we have them as a "Therapist" in both locations in Keet?
    • That is correct. Our current system is "location centric." If these providers see patients at both of your locations then you will see them reported twice. If you do not have them at multiple locations, Keet should be notified via support ticket so we may investigate. Sorting by location is the best way to reconcile these. We will merge the patients reported for each location when we submit final aggregate data to Medicare under each provider NPI. You do not need to do anything.
  • Since I've sent you that process report a couple of months ago, we've been working through it and disqualifying the appropriate patients. However, on the Compliance Report, it only shows that a total of 4 patients have been disqualified. Does it not include already disqualified patients or did we do something wrong when applying the DQ tag in Keet?
    • Keet created a disqualified checkbox mid year. If clients continued to use the DQ tag after the initiation of the checkbox, the patients will not be identified as disqualified. Keet can run a report for clients to identify all patients with a DQ tag.

  • A Therapist was terminated in April of 2019, so we cannot consult her for her clinical judgement on whether her patients should be disqualified. Do I need to do anything special in this case?
    • If a provider did not personally treat the patient they cannot retrospectively infer clinical judgement for the denominator exception criteria "PT/OT can use their clinical judgement to exclude patients who are extremely medically complex, who in their experience are likely to make poor clinical progress." However, another provider could potentially disqualify a patient treated by another provider if there is clear documentation in the medical record that the patient had a frank exclusion criteria. Examples that come to mind are non-English-speaking or illiterate patients. If you have reason to believe the Therapist treating the patient was not disqualifying patients with obvious exclusion criteria you could possibly embark on the exercise of reviewing the patient medical records and disqualifying patients that have an exclusion criteria clearly documented in the medical record. Keet recommends that you carefully consider this option based on the compliance implications of revising patient data.

  • I assume a terminated Therapist's data will influence our overall outcomes despite not being with us anymore?
    • You are correct that their performance will be included in the overall performance rate for the Group NPI.

  • Two of our Therapists aren't on the patient info summary report at all. I believe this is because when we set them up in Clinicient, they were NOT listed as Supervising Therapists. This is because they needed all their notes cosigned by a Therapist that was credentialed with insurances already. They are still currently having all of their notes cosigned. Is my assumption correct as to why they aren't on the sheet?
    • That is correct!

  • Do I need to have the co-signing Therapist mark which patients are theirs and label those as "change NPI to" on the final MIPS sheet or just leave them the way they are now?
    • If you have Therapists that are not credentialed with Medicare or assigned to your Group NPI (i.e. per diem/locum tenens providers) that treat and bill in collaboration with other providers in your group ) then you should submit the patient data under the Supervising Therapist. This may be a little nuanced so we are happy to discuss this further as needed.

  • I have a client who is stating that if a patient initially qualifies for MIPS, then drops out of treatment after 3 or 4 visits, they go back and disqualify them. Am I correct in thinking that this isn't the proper way to do that? My thinking is that this would be the same as changing a piece of documentation after it is completed. Do we know in this situation what the ideal course of action would be?
    • See our article on Disqualifying a patient. Clinics and Therapists should not be disqualifying patients unless there is a valid reason for this as outlined in our article.

  • Do we have to formally opt into MIPS?
    • No. Providers officially opt in by submitting their data to Medicare at the end of the year (which Keet will do on their behalf).

  • Is there any way to get MIPS 2019 data out of Clinicient?
    • Clinicient did not support MIPS submission. To determine whether your clinic was required to participate, check your QPP Participation Status here: https://qpp.cms.gov/participation-lookup. We advise you to plan for 2020 reporting as we have already passed our deadline for taking on new clients.

  • We noticed that the patients that completed one Pro have not been disqualified yet.
    Will Keet be handling this or do our Clinicians need to mark them as disqualified?
    • Patients who have less than 2 completed PROs are automatically excluded. They are shown on the summary report as all data for the year is included although are excluded from reporting as are patients under the age of 18. The disqualified column indicates if the patient has been manually disqualified in Keet via the Disqualified checkbox. You don't need to manually disqualify them as they will be automatically excluded.

  • 4 of our 9 therapists did not meet the minimum 39% compliance threshold per Medicare guidelines. In this case, should we only submit data for the 5 therapists that did meet the compliance threshold? If so, will this be done for us by Keet automatically or do we need to specify that we would like to do this?
    • The client will want to evaluate if their group as a whole was below the non-compliance rate of 39%. If so, they may want to report as a group or select the "both" option. If they aren't below the 39% threshold, they will want to report by individual. This will also be informed by which providers are required to participate.

  • In reviewing our Therapist Failure-to-Progress Report, it appears that we have a number of Therapists who did not meet the recommended failure to progress criteria for a number of different PROs. In this case, assuming that we do submit our data to CMS, can this data actually be used to penalize us in the future or is this year’s data only being used for analysis purposes? In other words, might it not be in our best interest to submit this year?
    • They will not be penalized if they surpass the FTP benchmark. In this scenario, the provider would not receive any of the available 7 points for that measure. If they are below the FTP benchmark, they will earn up to 7 points per measure. The further below the FTP benchmark, the more points will be awarded.

  • The disqualified column indicates if the patient has been manually disqualified in Keet via the Disqualified checkbox” what if that column is blank?
    • The disqualified column and the disqualify column are different. The difference being that disqualified comes from the flag in the UI, of which is populated for you in your report. The disqualify column is where you elect to populate "yes" if you would like to override and disqualify the patient given proper documentation.

  • Within the reports, is the date in the "Started At" column the date of the initial evaluation or the date the first PRO was created?
    • This is the date of the patient's initial evaluation within the episode of care.