Revenue Cycle Management Blog | GroupOne Health Source

Are You Exempt from the Merit-Based Incentive Payment System?

Written by Kaitlyn Houseman | May 11, 2017

Still wondering if you need to participate in the Merit-based Incentive Payment System? You're not alone. The transition from Meaningful Use, PQRS, and VBM programs all seemed to happen rather quickly and the MIPS scoring methodology has a number of healthcare professionals wondering if participating is even worth the headache. Fortunately, CMS announced that the official Quality Payment Program participation letters will be sent to eligible clinicians in late April through May to inform clinicians if they are required to participate.

What is the Merit-based Incentive Payment System?

The Merit-based Incentive Payment System (MIPS) was created by the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 to streamline multiple value-based programs including Meaningful Use (MU), Physician Quality Reporting System (PQRS) and Value-Based Modifier (VBM).

According to CMS, nearly 600,000 clinicians will participate in MIPS under the Quality Payment Program.

Related: How to Pick Your Pace for the Quality Payment Program

What is the purpose of the QPP participation letters from CMS?

The Quality Payment Program participation letters will inform clinicians if they are required to participate in the Merit-based Incentive Payment System (MIPS) in 2017 or if they are exempt from MIPS because they fall below the low-volume provider threshold. 

What is the low-volume provider threshold?

Clinicians that bill less than $30,000 in Medicare Part B allowed charges or who provide care for 100 or fewer Medicare Part B enrollees during either of the two previous years. If a clinician meets any one of those two thresholds then they are exempt from MIPS under the low-volume provider exemption. This threshold is the same whether the clinician reports individually or as a group.

When will the participation letters be sent?

The Centers for Medicare and Medicaid (CMS) announced that the official Quality Payment Program (QPP) participation letters will be sent to eligible clinicians in late April through May. The letters will be sent by the Medicare Administrative Contractor (MAC) that processes the clinician’s Medicare Part B claims. 

Will CMS continue to send letters on exemption?

In future years, CMS intends to send letters in December so that providers will know in advance whether they are exempt for the upcoming reporting year.

How can I find out today if I am exempt from MIPS?

Don’t feel like waiting for your letter? CMS has set up a web page where you can check to see if you need to submit data to MIPS. You will need to enter your 10-digit NPI in order to make this inquiry. 

Related: A Cheat Sheet to the Merit-Based Incentive Payment System [Infographic]

Important Dates to Remember for MIPS

If you choose to participate in the Merit-based Incentive Payment System, you will be responsible for sending accurate data by the following deadlines to earn a positive Medicare payment adjustment by 2019:

  •     October 2, 2017: Eligible Providers have until October 2, 2017 to begin recording quality data and how technology was used in their practice to improve performance.
  •     March 31, 2018: Send performance data for MIPS and receive feedback on your performance from CMS within the same calendar year.
  •     January 1, 2019:  Positive MIPS payment adjustments begin January 1, 2019 if you submit your 2017 data by March 31, 2018.

If you opt to take part in MIPS, your Medicare Part B payment amounts will be based on your performance and the value you give to your patients. MIPS value metrics will be measured in four categories: quality, cost, advancing care information, and improvement activities.

Please note, the following groups are not eligible to participate in MIPS:

  •     Physicians in their 1st year of Medicare Part B participation
  •     Physicians whose practice falls below the low patient volume threshold with Medicare billing charges less than or equal to $10,000 or if you provide care for 100 or fewer Medicare patients annually.