MIPS Reporting Challenges & Solutions in 2025 for PT & OT Providers | TriumpHealth

The Merit-based Incentive Payment System (MIPS) continues to evolve, presenting new opportunities and challenges for physical therapists (PTs) and occupational therapists (OTs) in 2025. As an integral part of Medicare’s Quality Payment Program (QPP), MIPS reporting requires strategic planning to ensure compliance, optimize performance scores, and avoid penalties. This guide outlines the updated reporting criteria, key challenges, and effective solutions for PT and OT providers navigating MIPS in 2025.

Understanding MIPS Reporting for PT & OT Providers in 2025

MIPS evaluates eligible clinicians across four performance categories, each contributing to the final MIPS score:

1. Quality (30%): PTs and OTs must report on six quality measures, ensuring at least one is an outcome or high-priority measure. CMS requires reporting for at least 75% of eligible encounters across all insurance types.

2. Promoting Interoperability (25%): In 2025, PTs and OTs will fully participate in this category, requiring adherence to Certified Electronic Health Record Technology (CEHRT) and patient data exchange requirements.

3. Improvement Activities (15%): Engaging in practice improvements, such as adopting interoperable clinical decision support tools and care coordination programs, will be essential.

4. Cost (30%): New cost measures will apply, including those assessing care episodes related to rehabilitation and therapy interventions.

The performance threshold remains at 75 points to avoid penalties, with a 9% maximum penalty and potential incentives for high performers.

Key MIPS Reporting Challenges for PT & OT Providers in 2025

1. Limited Specialty-Specific Measures

While some therapy-specific quality measures exist, they may not fully reflect all practice areas, requiring PTs and OTs to select measures that do not align with their patient population.

2. Complexity of the Cost Performance Category

Capturing accurate cost data is challenging due to variations in:

• Facility fees (clinic vs. hospital-based therapy)
• Equipment and assistive devices costs
• Post-treatment care expenses

The Low Back Pain (LBP) cost measure remains the only therapy-specific cost measure, requiring providers to meet a minimum of 20 patient episodes to be scored.

3. Data Collection and Documentation Burden

• Ensuring comprehensive documentation to support quality measures is critical, particularly for complex cases requiring long-term follow-up care.
• The 75% data completeness requirement for all eligible patients increases the administrative workload.

Interpretation of Scoring Methodology

Understanding how CMS calculates cost performance scores remains complex, especially in the areas of episode-of-care attribution and risk adjustment factors.

Navigating Promoting Interoperability Requirements

First-time full participation in this category means that PTs and OTs must ensure proper implementation of CEHRT and electronic exchange of health records.

Small practices with 15 or fewer clinicians may qualify for automatic reweighting, but submitting any data will negate the exemption.

Keeping Up with CMS Updates

New MIPS Value Pathways (MVPs), such as the Rehabilitative Support for Musculoskeletal Care MVP, will allow benchmarking against similar providers.

CMS plans to phase out traditional MIPS in future years, making early adoption of MVPs essential.

Strategies for Overcoming MIPS Reporting Challenges

1. Engage with Professional Organizations

Stay updated on MIPS changes through organizations like the American Physical Therapy Association (APTA) and the American Occupational Therapy Association (AOTA).

2. Utilize MIPS Consulting Services

Working with MIPS consulting services for PT & OT providers ensures accurate reporting, optimized performance scores, and reduced compliance risk.

3. Implement Robust EMR Systems

Leveraging affordable MIPS reporting solutions for PT & OT providers can simplify data collection and automate measure submissions.

4. Optimize Cost Performance Scores

Understanding Medicare incentives program guidelines helps identify areas for cost reduction, such as minimizing unnecessary tests and improving care coordination.

5. Leverage MIPS Value Pathways (MVPs)

MVPs provide specialty-focused reporting options with reduced administrative burden and enhanced performance feedback.

6. Seek Comprehensive MIPS Attestation Support

Ensuring compliance with MIPS attestation requirements prevents costly penalties and enhances reimbursement opportunities.

Conclusion

MIPS reporting in 2025 presents both challenges and opportunities for PTs and OTs. While limited specialty-specific measures, documentation burdens, and cost complexities create obstacles, strategic use of consulting services, MVP participation, and robust data collection systems can significantly improve performance. Staying informed and leveraging MIPS consulting services for independent healthcare providers will be key to achieving success in the evolving Medicare landscape.