If there’s one thing that’s certain in healthcare, especially right now, it’s that everything is uncertain. This is evidenced by the fact that CMS has finally sent letters to more than 800,000 clinicians saying they will NOT be evaluated by MIPS in 2017 after all. This brings the total number of participating clinicians down to 418,849.
With the high costs of MACRA compliance — experts claim it will cost the industry $1.3 billion — CMS has reformulated the estimates of providers’ Medicare revenue, which is the reason for the fluctuation of eligible participants (originally estimated at 642,000).
These letters were expected from CMS months ago, back in December 2016. CMS missed its initial deadline, causing frustration for many, including The Medical Group Management Association (MGMA). The organization sent a letter to CMS back in March attempting to get an immediate release on eligibility notifications. In the note addressed to CMS Administrator Seema Verma, MGMA says:
“Contrary to the Agency’s own regulatory provisions and commitment to providing notifications last December, it is now three months into the 2017 performance period and CMS has failed to notify clinicians and group practices regarding low volume threshold exemptions, status as hospital-based or non-patient-facing, as well as approved lists of registry vendors. … Without basic information about eligibility, physicians and medical groups are significantly disadvantaged from positioning themselves for success in the program.”
Better late than never, the letters finally came. Below is an outline of who is exempt and who is still eligible for MIPS participation.
MIPS exemptions include those in their first year of Medicare Part B participation, ie. those who charge Medicare less than $30,000 per year and provide care for fewer than 100 Medicare B patients in a year. Other exemptions include Accountable Care Organizations (ACOs) in Track 2 or 3 of the Medicare Shared Savings Program and medical homes in CMS’ Comprehensive Primary Care Plus program.
And, because MACRA law requires participation in MIPS or participate in an Alternative Payment Model (APM) or Advanced APM, APM participants and those with certain bundled payments agreements are also exempt. MIPS does not apply to hospitals.
Who is still required to participate in MIPS? Eligible clinicians included Physicians (MD/DO and DMD/DDS), Physicians Assistants, Nurse Practitioners, Clinical Nurse Specialists, and Certified Registered Nurse Anesthetists, as well as those who participate in Medicare Part B and charge more than $30,000 per year.
→ Are you eligible to participate in MIPS? Medscape has created this handy tool to check and see.
How MIPS works
Data is reported in four categories: Quality (60% in 2017; 50% in 2018); Advancing Care Information (25%); Clinical Practice Improvement Activities (CPIA, 15%); and Resource Use/Cost (10%).
The max score is 100. The higher your MIPS score, the better the payment adjustment following the performance year (up to 5%). Meanwhile, not participating in MIPS could mean a 4% negative payment adjustment.
MIPS participants need to select six different measures in the Quality Performance category to report to CMS. Of these six measures, one must be an outcome measure and one must be considered high-priority. This can be an outcome, appropriate use, patient experience, patient safety, efficiency, or care coordination measure.
The MIPS performance period began January 1, 2017, and runs through December 31, 2017. The data submission deadline is March 31, 2018, and the payment adjustment period will begin in January of 2019.
Guess what? Not only is CODE Technology a patient-reported outcome (PRO) vendor that handles everything as a service, CODE is also an official Qualified Clinical Data Registry (QDCR) for MIPS. This means we can submit patient-reported outcome data to MIPS on our client’s behalf, which is super-exciting! Click here to see the MIPS measures CODE reports on.