CMS Posts MIPS Participation Status Determinations

The Centers for Medicare and Medicaid Services (CMS) has sent letters to each eligible clinician (EC) which states if they have to participate in the Medicare Merit-based Incentive Payment System (MIPS) in 2017. The letters will also state if ECs are exempt from some of the reporting requirements or from the program entirely for the 2017 reporting year.
These letters were originally supposed to be sent by the end of 2016.
CMS has also created a tool on its official Quality Payment Program (QPP) website where ECs can look up their participation status by their national provider identifier (NPI) number.
For those required to participate, data reported under MIPS in 2017 will affect Medicare payments by as much as -4 or +4 percent in 2019. Some providers will have their reporting requirements reduced for reasons such being a non-patient-facing clinician or being a hospital-based provider. Others will be completely exempt from MIPS if they fall below a low volume threshold.
EC provider types required to participate in MIPS in 2017 are:
 Physicians
 Physician assistants
 Nurse practitioners
 Clinical nurse specialists
 Certified nurse practitioners
ECs are required to participate in MIPS in 2017 if they:
 Bill Medicare Part B more than $30,000 a year AND
 See more than 100 Medicare patients a year.
Falling below either of those figures will exempt an EC from MIPS in 2017. Participation determinations will be made each year. The low-volume exemption threshold applies the same regardless of whether an EC participates individually or as a group.
CMS is exempting almost two thirds of ECs from MIPS reporting in 2017 under the low-volume threshold. To be exact, 806,879 ECs will be exempt while 418,849 will be required to report.
2017 is the first year ECs have to report under MIPS. CMS has made 2017 a transition year which gives ECs several participation tracks. ECs can elect to report minimal data to avoid a negative payment adjustment or report for longer periods of time during the reporting year to be eligible for a larger portion of the maximum possible positive payment adjustment of +4 percent. ECs who are required to report who fail to report any data will receive the maximum negative payment adjustment of -4 percent.
The MIPS payment adjustments are budget neutral meaning that the negative payment adjustments fund the positive payment adjustments. The transition year greatly reduces the number of ECs projected to receive a penalty which means that there will likely be very little money available for positive payment adjustments in 2017.
If these assumptions hold true, the only way for ECs to earn a substantive positive payment adjustment will be if they qualify for the bonuses that are available to the highest performers. This bonus money is not subject to the budget neutrality of MIPS.
CMS officials have stated that they intend to hold a second round of eligibility determinations which would only add to the list of ECs receiving an exemption and will not remove an exemption that has already been determined.
ECs who do not agree with their participation status determination can contact the CMS support desk by emailing QPP@cms.hhs.gov or by calling 1-866-288-8292.

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