- CMS anticipates notifying eligible clinicians about their Merit-Based Incentive Payment System (MIPS) participation status for 2017 via letter between late April through May, a recent email from the federal agency stated.
The announcement (via AHA News Now) said that eligible clinicians should expect a letter from the Medicare Administrative Contractor who processes their Part B claims. The letter will contain the MIPS participation status of each eligible clinician associated with the Taxpayer Identification Number (TIN) in the healthcare organization.
The CMS plan for MIPS participation status notifications came about a month after the Medicare Group Management Association (MGMA) urged the federal agency to release eligibility statuses.
In a letter to CMS Administrator Seema Verma, the industry group pointed out that CMS committed to providing MIPS participation notifications in Dec. 2016. But three months after the start of the 2017 MIPS performance period, eligible clinicians still had not heard from the federal agency.
“Without basic information about eligibility, physicians and medical groups are significantly disadvantaged from positioning themselves for success in the program,” the organization wrote.
MGMA also called on CMS to release approved vendor lists for MACRA reporting and hospital or patient-facing status notifications. Both the vendor lists and hospital or patient-facing notifications would alter MIPS reporting requirements for eligible clinicians.
Although the federal agency noted in its email announcement that some providers should expect to submit data to MIPS in 2017 based on low-volume thresholds. Physicians, physician assistants, nurse practitioners, clinical nurse specialists, and certified registered nurse anesthetists who annually bill more than $30,000 in Medicare Part B allowed charges and care for over 100 Part B-enrolled Medicare beneficiaries a year should expect a MIPS participation status letter.
According to a CMS fact sheet, the federal agency will use the following data to determine low volume thresholds for the 2017 performance period and 2019 payment year:
• Historical claims data from Sept. 1, 2015 to Aug. 1, 2016
• Performance period claims data from Sept. 1, 2016 to Aug. 31, 2017
However, providers who do not meet MIPS participation requirements or enrolled in Medicare for the first time in 2017 will not be eligible for the value-based reimbursement program.
In addition, CMS plans to exempt providers who significantly partake in an Advanced Alternative Payment Model (APM), the other value-based reimbursement track in the Quality Payment Program. Advanced APM participation requirements include receiving 25 percent of Medicare payments or treating 20 percent of Medicare beneficiaries through an approved Advanced APM in 2017.
The federal agency expects more than half of clinicians billing under the Medicare Physician Fee Schedule to be excluded from MIPS participation in 2017 because of MACRA exemption provisions.
About 200,000 clinicians, or 14.4 percent, are not eligible for MIPS participation in 2017 because of clinician type. Another 32.5 percent of clinicians billing Medicare Part B will also not participate because of their low-volume threshold.
Additionally, CMS plans for about 5 percent to 8 percent of all Medicare Part B clinicians to participate in an Advanced APM.
While some clinicians are not required to participate in MIPS, CMS encourages exempted providers to submit some data to MIPS. The federal agency plans to broaden MIPS participation as the Quality Payment Program matures and voluntarily MIPS reporting would help.
“Clinicians who are not included in MIPS now, may choose to voluntarily submit data individually to Medicare to learn, to obtain feedback on quality measures, and to prepare in the event MIPS is expanded in the future,” CMS wrote in the fact sheet. “Clinicians who submit data voluntarily will not be subject to a positive or negative payment adjustment.”