MGMA to CMS: Notify Clinicians About MIPS Eligibility ASAP

March 16, 2017 - The Medical Group Management Association (MGMA) recently called on CMS Administrator Seema Verma to immediately release Merit-Based Incentive Payment System (MIPS) eligibility notifications as well as approved vendor lists and hospital or patient-facing status.

MACRA’s Quality Payment Program launched on Jan. 1, 2017, but eligible clinicians have yet to find out if they qualify to participate in the program’s first performance year under the MIPS track.

“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,” the organization wrote.

“Without basic information about eligibility, physicians and medical groups are significantly disadvantaged from positioning themselves for success in the program,” they added.

Almost one-third of Medicare clinicians will not qualify to participate in MIPS in 2017 based on low volume thresholds, CMS stated in the MACRA implementation final rule.

READ MORE: CMS Timelines for Stage 3 Meaningful Use, MACRA Implementation

As part of the final ruling, the federal agency developed low-volume thresholds to ensure that eligible clinicians in MIPS have enough patient cases or Medicare revenue at stake to meaningfully participate in MIPS.

For 2017, eligible clinicians must receive at least $30,000 in Medicare Part B allowed charges or see at least 100 Medicare patients to join MIPS.

In total, CMS anticipates about 738,000 to 780,000 clinicians billing under the Medicare Physician Fee Schedule to be excluded from MIPS based on several factors. But the low-volume threshold will exclude the largest number of clinicians.

The final rule also stated that CMS would notify eligible clinicians of their MIPS eligibility status during the month before the start of the performance period. With MIPS performance periods starting in January, eligible clinicians should expect to hear from the federal agency in December.

However, MGMA noted that CMS has yet to contact clinicians about their eligibility for the first MIPS performance year.

READ MORE: What We Know About Value-Based Care Under MACRA, MIPS, APMs

Without a definitive call on their eligibility, CMS may not be setting up some eligible clinicians for MACRA success, the organization argued. Eligible clinicians need to prepare their organizations for MACRA by upgrading EHR systems, redesigning clinical workflows, installing appropriate data capture and reporting capabilities, partnering with appropriate data registries, and educating staff.

But with eligibility still up in the air, some clinicians may find it difficult to implement the proper clinical changes, especially if they think they may not even qualify for MIPS participation.

In addition, MGMA pointed out that CMS has failed to release a list of approved data registries for the 2017 MIPS performance year. Like the MIPS exclusion provision, CMS stated in the final rule that it would publish a list of qualified registries and qualified clinical data registries that clinicians could partner with to receive MIPS performance points.

MIPS eligible clinicians can use an approved vendor to submit their performance data. CMS listed qualified clinical data registries, health IT vendors, qualified registries, and CMS-approved survey vendors as reporting mechanisms for MIPS performance data.

Eligible clinicians can also earn bonus points under the MIPS Advancing Care Information category for using a clinical registry. Reporting on at least one Public Health and Clinical Data Registry measure will boost a clinician’s score by 5 percent.

READ MORE: Key Ways to Succeed Under MACRA’s Quality Payment Program

However, the absence of an approved registry and vendor list hinders eligible clinicians from carrying out MIPS reporting requirements.

“Group practices planning to utilize these reporting mechanisms must either delay engagement or partner with vendors without a guarantee they meet CMS’ qualifications,” MGMA stated.

Additionally, MGMA urged CMS to release hospital-based and non-patient-facing status notifications. Eligible clinicians that qualify for the two statuses will report on different MIPS measures than other eligible clinicians.

For example, hospital-based clinicians do not need to report on the MIPS Advancing Care Information category because the measures do not appropriately apply to the clinician group. Instead, CMS plans to shift the percentage weight of the category to the MIPS Quality component.

Similarly, MIPS measures may not apply to many non-patient-facing clinicians. Therefore, CMS adjusted the measure sets for these clinicians, including only requiring them to report one high-weighted or two medium-weighted MIPS Improvement Activities. MIPS eligible clinicians face greater Improvement Activities reporting.

But, like MGMA argued previously, not knowing if a clinician qualifies for these statuses impedes their MIPS participation.

“Due to the nature of clinical practice, these clinicians and group practices are unable to comply with certain program requirements and are afforded necessary flexibilities,” wrote the organization. “To date however, they do not know their MIPS status and the pertinent rules under which they must comply.”

MGMA intends for the letter to CMS to expedite the notification process and help eligible clinicians succeed under MACRA.