Medicare Compliance & Reimbursement

If you’re shy of the low-volume threshold numbers to be part of the Merit-Based Incentive Payment System (MIPS) for performance year (PY) 2020, you may still be able to send your measures.

Background: In order to participate in MIPS for the PY 2020, your Medicare Part B claims must show the following three low-volume threshold requirements during either of the two determination periods, October 1, 2018 – September 30, 2019 or October 1, 2019 – September 30, 2020:

1. Bill $90,000 in Part B allowed charges.
2. Administer care to at least 200 Part B beneficiaries.
3. Provide at least 200 covered fee-schedule services to Part B patients.

The Quality Payment Program (QPP) offers a handy tracking tool if you aren’t sure whether or not you’ve met the PY 2020 thresholds. With your National Provider Identifier (NPI), you can check your MIPS eligibility status using the QPP lookup tool at https://qpp.cms.gov/participation-lookup/.  

But: Another thing the QPP participation status tool identifies is whether you or your group practice can elect to “opt-in” or voluntarily submit MIPS measures for PY 2020. According to QPP guidance, you must meet one or two of the threshold requirements to opt-in; plus, at least one clinician must be:

• identified as a MIPS-eligible clinician type on Medicare Part B claims;
• enrolled in Medicare before 2020;
• not a QP; and
• not a participant in one or more MIPS APM entities.

Caveat: If you do opt-in to MIPS 2020, you’ll receive a payment adjustment, which can be positive, neutral, or negative. However, if you don’t meet any low-volume threshold criteria, aren’t “opt-in eligible,” and choose the voluntary report route, you won’t get a MIPS payment adjustment, QPP guidance suggested. Additionally, “once made, your election is binding and irreversible,” a QPP alert cautioned.

If you decide to submit data, the PY 2020 MIPS submission window opens on Jan. 4, 2021.