The Centers for Medicare and Medicaid Services (CMS) has proposed a rule that would affect the 2018 reporting year and beyond. The proposal offers a number of ways to help physicians avoid penalties. CMS has posted a fact sheet about its proposal.
The Centers for Medicare and Medicaid Services (CMS) says over 33,600 psychiatrists provide services reimbursed under Medicare Part B. The Merit-based Incentive Payment System (MIPS) is part of Medicare’s new Quality Payment Program (QPP). MIPS payment adjustments begin in 2019, and depend on your performance score from two years earlier. So now is the time to take action to avoid penalties in 2019.
How to avoid the MIPS penalty?
Must I Do MIPS Reporting to Avoid Future Penalties?
Yes: For 2017: I am a physician, physician assistant, nurse practitioner, or clinical nurse specialist, and I (or my group practice) have over 100 Medicare Part B patients AND over $30,000 in Part B allowable charges per year. These include separate Part B payments/patients seen through federally qualified health centers (FQHCs) and rural health centers (RHCs). This is a great year to try out MIPS reporting, since less is required to avoid future penalties.
For 2018 & Beyond: The low-volume threshold MAY increase to $90,000/200 patients per
year.
I am a “partially qualifying participant” in an Advanced Alternative Payment Model and I choose to participate in MIPS reporting.
This is a great year to try MIPS reporting. Minimal reporting is needed to avoid a future penalty. And it is good preparation for when other payors adopt quality programs similar to MIPS.
Many exempt
Several classes of physicians, accounting for about two-thirds of the clinician population, are exempt from MIPS and QPP reporting. These include:
- Physicians who practice exclusively in Rural Health Clinics or Federally Qualified Health Centers.
- Physicians enrolling in Medicare for the first time during a MIPS reporting period.
- Those who bill only $30,000 or less in Part B charges or who have only 100 or fewer Part B-enrolled Medicare beneficiary patients.
- Those participating in an advanced alternative payment model (APM).
- Non-patient-facing specialists who bill for only 100 or fewer patient-facing encounters during a reporting period.
Physicians can check their MIPS status by entering their National Provider Identifier into the CMS QPP portal.
It’s unknown what kind of transitional allowances might be developed for 2018, so physicians are encouraged to practice filing quality measures in preparation for when full reporting is required.
What Should I Report to Avoid a MIPS Penalty?
To avoid 2019 MIPS penalties, you only need to do ONE of the following:
- Report ONE quality measure for ONE patient – Via claims, electronic health record (EHR), qualified data registry, or qualified clinical data registry (QCDR).
- Report ONE improvement activity — Submit an attestation (marked “Yes”) that you have
performed the activity for at least 90 days, to CMS via the QPP website, EHR, qualified registry, or QCDR. - Report ALL base score measures for the advancing care information category, for use of
certified electronic health record technology (CEHRT), for part of 2017.
CMS Proposed Quality Payment Program Rule For Providers 2018
On June 20, 2017, The Centers for Medicare and Medicaid Services (CMS) released the 2018 Quality Payment Program (QPP) proposed rule, which proposes policies for the Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Model (APM) programs 2018 to impact 2020 Medicare physician payments.
It doesn’t seem that long ago when MACRA was first announced and the final rule was released last October. But now, providers are anticipating what’s ahead for the program in its second year, especially for the Quality Payment Program. The healthcare industry received its first glance at what’s in store for 2018 as CMS released the QPP proposed rule earlier this week.
Read our blog post to more about on CMS https://wonderws.com/cms-releases-2018-proposed-quality-payment-program-rule/
CMS Final 2019 MIPS Rules Are Here – What You Need to Know
CMS has made several changes to the 2019 Merit-based Incentive Payment System (MIPS) as part of the final 2019 Medicare physician fee schedule. While CMS did not finalize any sweeping changes to the program, physicians should be aware of changes to MIPS weights and scoring, the low-volume threshold exemption, and other provisions that will impact reporting in 2019.
Changes to MIPS performance weights and scoring
CMS has announced that the minimum score necessary to avoid a penalty in 2021 (reporting in 2019) is 30 points — this is twice the 2018 threshold of 15 points. The minimum required number of points to be eligible for the exceptional score bonus is 75.
CMS also finalized its proposal to reduce the weight of the Quality category from 50% to 45% and increase the Cost category from 10% to 15%.
Tweaks to the MIPS low-volume threshold exemption
CMS added an opt-in opportunity for physicians and providers who want to participate in MIPS but meet the low-volume threshold exemption criteria.
If a MIPS-eligible clinician meets or exceeds one, but not all, of the low-volume threshold exemption criteria — as defined by dollar amount ($90,000), beneficiary count (200), or covered professional services to Part-B enrolled individuals (minimum threshold of 200) — then the clinician may elect to submit data and opt-in to MIPS.
If a clinician does not meet at least one of these low-volume determinations — or meets at least one, but not all, of these low volume determinations and elects not to opt-in — the clinician is not eligible and is excluded from MIPS.
At WWS, we understand not only how important it is to avoid penalties, but how to help you stay compliant where any billing issue is present.
Feel free to Schedule a Strategy Meeting with us today to find out more about what we can do for you.