MIPS Manual 2017—Know the Basics: Who Does (and Doesn’t) Take Part in MIPS

This content was excerpted from EyeNet’s MIPS Manual 2017.

MIPS introduces a new term—the MIPS eligible clinician. MIPS eligible clinicians are defined as physicians (which, for this purpose, includes optometrists), physician assistants, nurse practitioners, clinical nurse specialists, and certified registered nurse anesthetists, as well as groups that include such clinicians.

Not all MIPS eligible clinicians must participate in MIPS. You are exempt from MIPS if at least 1 of the following 3 exclusions applies.

Exclusion 1—MIPS eligible clinicians who are new to Medicare. If you enroll in Medicare for the first time in 2017, and you have not previously submitted claims under Medicare, you will be exempt from the MIPS rules for the 2017 performance year. Furthermore, MIPS eligible clinicians who enroll in Medicare toward the end of 2017 may also fall within the low-volume exemption for the 2018 performance year.

Exclusion 2—MIPS eligible clinicians who are below the low-volume threshold. You will be exempt from the MIPS rule if, over a 12-month period (see below), you:

• receive no more than $30,000 from Medicare Part B, or

• care for no more than 100 Medicare Part B beneficiaries.

You have 2 12-month periods to qualify for the low-volume exclusion. To see if you are exempt for the 2017 performance year, CMS will review your data for 2 time periods:

• Sept. 1, 2015, to Aug. 31, 2016

• Sept. 1, 2016, to Aug. 31, 2017

If you are below the low-volume threshold during either of these time periods, you will be exempt—even if you surpass the threshold in the other time period.

Exclusion 3—MIPS eligible clinicians in advanced APMs. If you are participating in an advanced APM (see “The Alternative to MIPS: APMs in Brief”), you may be exempt from the MIPS rule if you satisfy the APM track’s reporting thresholds.

Do you need to take part in MIPS? In May, you should have received a letter from CMS indicating whether you are a MIPS eligible clinician and whether any of the 3 exclusions apply to you. This information is also available online: Visit https://qpp.cms.gov/learn/eligibility and enter your 10-digit National Provider Identifier. Later this year, CMS will perform a second review of clinicians—reviewing services provided from Sept. 1, 2016, to Aug. 31, 2017 (see “Exclusion 2,” above)—to see if any providers should be added to the low-volume exclusion list.

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Next: Know the Basics: Use of TINs and NPIs as Identifiers

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