The MIPS Eligibility Evolution 2018 – 2021

Part 3:  This week we turn our attention to the evolving MIPS eligibility guidelines and impact on your practice. We covered the financial and reputational impact of the MIPS program last week, and highlighted AssuranceMD MIPS “Success as a Service” to prepare you and your practice for Quality Payment Program Year Two – and beyond.

The Challenge

Although CMS released the MIPS structure almost three years ago, the quality payment program continues to evolve. A dramatic example of the evolution is the eligibility criteria changes. Last fall CMS significantly expanded the low-volume threshold to exclude clinicians with either $90,000 or less in Medicare Part B allowed charges, or 200 or fewer Part B enrolled Medicare patients – an increase from $30,000 or 100 beneficiaries in the prior “Transition Year.”

The exclusion for newly enrolled Medicare clinicians who are in their first Medicare Part B calendar year continues in 2018.

The challenge for you is to keep up with the evolution of MIPS and its impact on your practice without the “noise” and often conflicting messages leaking out of Washington. AssuranceMD MIPS Success as a Service not only creates a reporting strategy and plan for your practice, but also monitors the evolution of MIPS so you don’t have to.

What the Evolution Means for You

In 2018, if your Medicare Part B billing exceeds $90,000 or you provide services to more than 200 Part B patients, you are eligible for MIPS reporting. If you chose not to report, CMS will reduce your Medicare Part B reimbursement by 4% in 2019; increasing to 5% in 2020, 7% in 2021 and 9% in 2022.

To check your eligibility based on the current rules, CMS offers a “Lookup Tool” on their website. You can check your MIPS participation status by entering your NPI in the tool at https://qpp.cms.gov/participation-lookup

If you are eligible you can contact the AssuranceMD MIPS experts to discuss how our “Success as a Service” can help you develop a plan for MIPS reporting and update your plan as we monitor developments at CMS as the year progresses.

We are Here to Work with You

In addition to the evolving eligibility criteria, CMS can designate additional “MIPS eligible clinicians” starting in 2021. The current list of eligible clinicians includes:

  • Physicians:
  • Physician Assistants
  • Nurse Practitioners
  • Clinical Nurse Specialists
  • Certified Registered Nurse Anesthetists

The MACRA Final Rule provides the following specific examples of clinicians CMS may add starting in 2021:

  • Certified Nurse Midwives
  • Clinical Social Workers
  • Clinical Psychologists
  • Registered Dietitians/Nutritionists
  • Physical Therapists and Occupational Therapists
  • Speech/Language Pathologists
  • Qualified Audiologists

For eligible clinicians, the experts an AssuranceMD MIPS Success as a Service are available to work with you to develop a strategy and a plan to maximize your success under MIPS, and to provide access to resources that will ensure your reporting plan stays current with the evolving MIPS rules. Next week we will walk through how AssuranceMD MIPS Success as a Service develops a strategy and reporting plan specific to your practice.