Beginning January 1, 2022, clinical social workers (CSWs) will become eligible to participate in Medicare’s Quality Payment Program (QPP). NASW advocated for the inclusion of CSWs in the QPP and are pleased that they are now eligible. CSWs participate in the QPP through a system called the Merit-Based Incentive Payment System (MIPS). MIPS was designed to tie payments to quality and cost efficient care, drive improvement in care processes and health outcomes, increase the use of healthcare information, and reduce the cost of care. 15 other provider types participate in the QPP.
CSWs may participate in the QPP by earning a payment adjustment for Medicare Part B covered professional services based on a performance evaluation across different categories that focus on the quality of care provided to a patient.
What are the eligibility requirements?
To participate in MIPS, a CSW must:
- Be an eligible clinician
- Exceed the annual low-volume threshold as an individual or group:
- Bill more than $90,000 Part B covered professional services
- See more than 200 Part B patients
- Provide more than 200 covered professional services to Part B patients
Clinicians and groups must exceed 1 or 2 of the above thresholds to opt-in to MIPs eligibility and participation.
Which measures do CSWs report?
Medicare has identified 15 measures that CSWs may use to report quality services. Quality measures are used to measure outcomes and systems that are associated with the ability to provide high quality patient care. The CSW measure list includes the following:
- Advance Care Plan
- Documentation of Current Medications in the Medical Record
- Preventive Care and Screening: Screening for Depression and Follow-Up Plan
- Elder Maltreatment Screen and Follow-Up Plan
- Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention
- Dementia: Cognitive Assessment
- Dementia: Functional Status Assessment
- Dementia Associated Behavioral and Psychiatric Symptoms Screening and Management
- Dementia: Safety Concern Screening and Follow-Up for Patients with Dementia
- Dementia: Education and Support of Caregivers for Patients with Dementia
- Depression Remission at Twelve Months
- Child and Adolescent Major Depressive Disorder (MDD): Suicide Risk Assessment
- Adherence to Antipsychotic Medications for Individuals with Schizophrenia
- Tobacco Use and Help with Quitting Among Adolescents
- Preventive Care and Screening: Unhealthy Alcohol Use: Screening & Brief Counseling
How are measures reported?
Measures for CSWs are generally reported through Medicare Part B claims. CSWs may choose to report as an individual, with a group, or a virtual group.
What is the reporting period for MIPS?
The reporting period for MIPS is January 1 – December 31, 2022
What are the benefits and risks in participating in MIPS?
MIPS provides CSWs with an incentive to provide quality care by increasing their Medicare reimbursement up to 9 percent. However, if measures are reported incorrectly, they may receive a negative penalty adjustment up to a negative 9 percent.
To assist in avoiding a negative penalty adjustment and due to the complexities of reporting, NASW recommends the use of a mental health registry for the reporting of measures. A registry is a vendor that collects data from an eligible MIPS individual clinician, group or virtual group and submits the data to Medicare on their behalf. There is a fee associated with the use of a registry. The registries that report mental health and substance use disorder quality measures include, but are not limited to, the following:
- PsychPRO of the American Psychiatric Association, https://www.psychiatry.org/psychiatrists/registry
- Mental and Behavioral Health Registry of the American Psychological Association, https://mbhregistry.com/
- MIPS Solution by Mingle Health, https://minglehealth.com/products-services/mips-solutions/
When may I expect payment for reporting measures in 2022?
For 2022, Medicare will issue MIPS positive and negative payment adjustments in early 2024.
Where can I find help and additional information?
CSWs are encouraged to contact the QPP Service Center at 1-866-288-8292, Monday through Friday, 8 am to 8 pm ET or by email at QPP@cms.hhs.gov. Assistance is also available from NASW by emailing Mirean Coleman, Clinical Manager, at firstname.lastname@example.org or Denise Johnson, Senior Practice Associate, at email@example.com
For additional information on the QPP, review Quality Payment Program (QPP) Resources
Prepared by Mirean Coleman, LICSW, CT