The complexity of the MACRA framework starts with knowing which track to take. MIPS 2018 or Advanced APMs 2018. If you’re not part of an Advanced APM and you are billing CMS for services, you may be MIPS eligible. MIPS 2018 carries forward from where MIPS 2017 left off when it comes to exemptions, eligibility, and thresholds. Knowing if your practice and individual providers qualify under MIPS 2018 may have large financial impacts to providers and practices. Working with an organization that understands the MIPS 2018 framework and is technically enabled to handle collect and aggregate your data for submission will drive revenue back to the practice and make the whole MIPS 2018 process easy.
MIPS 2018 eligibility includes, Physicians, Physician Assistants, Nurse Practitioners, Clinical Specialist, Certified Registered Nurse Anesthetists. The definition of physicians still includes Doctors of Medicine, Doctors of Osteopathic Practitioners, Doctors of Dental Surgery, Doctors of Dental Medicine, Doctors of Podiatric Medicine Doctors of Optometry, and Chiropractors. For eligible MIPS 2018 clinicians, the real challenge is understanding thresholds and exemptions to make sure you need to report in 2018.
MIPS 2018 exemptions are carried forward from MIPS 2017 with no changes. Providers newly enrolled in Medicare during the performance year are exempt until the following performance year. This would not include those providers that are using their same NPI but billing under a new Tax identification number in the current performance year.
Under MACRA, those providers significantly participating in Advance APM’s are exempt from MIPS. Providers are significantly participating in an Advance APM if they receive 25% of the Medicare payments or see 20% of the Medicare patients through an Advanced APM. Understand if you’re significantly participating in an Advanced APM by utilizing the following site https://data.cms.gov/qplookup.
Thresholds under MIPS 2018 have increased allowing for more providers and practices to opt out of the program. The low volume threshold has moved to less than or equal to $90,000 a year in Medicare part B allowed charges or less than or equal to 200 Medicare Part B patients a year. CMS has a great website for checking your MIPS 2018 eligibility at https://qpp.cms.gov/participation-lookup/.
Finally, there is no change to the non-patient facing criteria from 2017 to 2018 MIPS. Therefore, if you have fewer than or equal to 100 patient facing encounters you are exempt from MIPS 2018. Both Virtual groups and Groups that have less than 75% of the NPI’s identified as non-patient facing providers that are billing under a TIN or established as a virtual group during the performance year are exempt from MIPS.