2020 MIPS accommodation - should we file?

The Center for Medicare Services (CMS) recently released an accommodation in regards to 2020 MIPS participation for groups who are unable to report complete data due to COVID-19.  While this provides necessary relief for those groups adversely impacted by COVID-19, the majority of Keet Clients will not need to take advantage of this offering. Keet clients performed exemplary in 2019, and a recent review of Keet clients' performance shows the same outlook for 2020 participation.

2019 was the first performance year that PTs, OTs, and SLPs could participate in MIPS and qualify for a positive payment adjustment with adequate performance. While some groups were required to participate, many chose to opt-in. That decision is due to the unique opportunity MIPS provides to counteract the CMS frozen fee schedule. Participating in the 2020 Performance Year submission of MIPS is still the best way to counterbalance the overall failure to increase the Medicare Fee schedule and the potential 8% cut that may be applied to physical therapy services starting in 2021.  

The 2019 Performance Year data¹ showed that 100% of Keet group submission clients met the positive payment threshold, and 98% qualified for the additional Exceptional Performance bonus (score of >75/100). The average group score for Keet clients was 91.20/100. In comparison, Medicare actuaries estimated the median MIPS performance score for the 2019 Performance Year to be 78.72 (actuary estimation made prior to COVID). High ranking scores provided Keet clients a valuable marketing opportunity to position themselves as top-performers in rehabilitation outcomes for referral sourcing, contract negotiations, and marketing. Keet believes there continues to be significant value in participating in MIPS if you are still able to meet the minimum reporting requirement of 70% of your eligible patients. Therefore, we suggest that you consider continuing to collect PROs and evaluate your reporting compliance over the next few months before making a final decision. As a reminder, you have until December 31st to file for the exemption. Participating this year is one of the last opportunities to maximize your bonus potential before the Exceptional Bonus funds are retired after the 2021 reporting year! 

Still unsure if you should file for the accommodation? Our team of MIPS analysts is here to assist you in that decision. Reach out to your Customer Success Manager, or to set up a one-on-one call with someone from our MIPS team, select a time here.

Find additional information on the application process here

¹CMS will publish final 2019 PY scores in October 2020 following the targeted review period.