MIPS: Eligibility and the Low Volume Threshold – What to Consider Now
November 8, 2016
Written by Sarah Leake
Let’s revisit Eligibility –
The following clinicians are considered eligible clinicians for the 2017 performance year –
- (MD/DO and DMD/DDS), Nurse Practitioners, Physician Assistants, Clinical Nurse Specialists, and Certified Registered Nurse Anesthetists
- Only those eligible clinicians in the categories above who bill for Medicare Part B (otherwise known as the Physician Fee Schedule) – including those billing using Critical Access Hospital (CAH) Method II payment methodology who have assigned their billing rights to the CAH
- Excluded from MIPS payment adjustments: Payments from Medicare Part A, Medicare Advantage Part C, Medicare Part D, FQHC or Rural Health Clinic facility payments billed under all-inclusive payment methodologies, and CAH Method I facility payments
CMS has set exemptions for “eligible clinicians” in the MIPS side of the Quality Payment Program which I have listed later in this blog. One in particular is the low volume threshold that can be applied at a provider or at a group level. Low volume thresholds are stated to determine if you will be participating as defined by CMS. “Clinicians exempt from MIPS do not meet the threshold to participate if they have ≤ $30,000 in allowed Medicare charges OR ≤ 100 Medicare patients.” Remember though, if you pick the group level for reporting, then all providers under that TIN will need to report at the group level. “
If you find that a clinician falls into the “not eligible” category due to low volume threshold, you may still choose to continue to monitor to align with your quality program, but this clinician will not be considered for payment adjustments in terms of reductions or incentives for the 2017 participation year. It is important to review your organization’s value based care strategy and financial situation to determine if “self participation” in the QPP program will fall into your goals and prepare you for future requirements and eligibility in reporting.
The 2017 QPP year is definitely flexible and not a “one size fits all” program so requires your analysis to determine your participation goals and plans.
Resource Links and Other Information
Here are the Exemptions from MIPS –
For the CY2017 performance year, there are three exemptions from MIPS for clinicians who otherwise meet the eligibility requirements –
- Clinicians in their first year of Medicare Part B participation
- Clinicians billing Medicare Part B up to $30,000 in allowed charges or providing care for up to 100 Part B patients in one year
- Clinicians in entities sufficiently participating in an Advanced APM If you fall into this category please check the Quality Payment Program website for more detail.
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