Small Practices May Be Exempt From CMS MIPS Program
The Merit-based Incentive Payment System (MIPS) is a Quality Payment Program that combines the existing Medicare Meaningful Use (MU), Physician Quality Reporting System (PQRS), and Value-Based Modifier (VBM) programs, and adds a fourth component to promote ongoing improvement and innovation to clinical activities.
MIPS eligible clinicians must report successfully on defined quality measures and activities of their choosing, or face potential negative payment adjustments in future years. For example, MIPS eligible clinicians who do not send in any 2017 data will receive a negative 4 percent payment adjustment in 2019 (based on Medicare Part B charges or Critical Access Hospital (CAH) Method II payments assigned to the CAH). Conversely, those who successful demonstrate quality and improvement under MIPS will enjoy payment incentives of up to 9 percent.
MIPS eligible clinicians include physicians, PAs, NPs, clinical nurse specialists, and certified registered nurse anesthetists who bill for Medicare Part B services (the number and type of MIPS eligible clinicians will expand in 2019).
Not all eligible clinicians are required to participate in the program in 2017. Those MIPS eligible clinicians excluded from the program include:
- Clinicians in their first year of Medicare Part B participation
- Clinicians billing Medicare Part B less than $30,000 in Medicare allowed charges, or providing care for fewer than 100 Part B patients in one year
Nearly half of those clinicians meeting such exclusions work in practices with fewer than 10 physicians; however, MIPS eligible clinicians who do not meet the above exemptions must report data, even if other clinicians in the same practice are exempt. Only if 75 percent or more of the eligible clinicians in a practice are exempt can the whole practice avoid MIPS.
Finally, clinicians in entities sufficiently participating in an advanced alternative payment method (APM) may be except from MIPS, if either:
- The collective Part B payments for services delivered by the Advanced APM entity’s clinicians to patients attributed to the entity is at least 25 percent of the payments for services delivered by the entity’s clinicians to all patients who could, but may not, be attributable to the entity (“attribution-eligible”)
- The collective number of patients who receive services delivered by the Advanced APM’s clinicians and who are attributed to the Advanced APM is at least 20 percent of the number of all patients who are attribution-eligible and received services delivered by the Advanced APM’s clinicians