The complexity of the MACRA framework starts with knowing which track to take: MIPS or Advanced APMs. If you’re not part of an Advanced APM and you are billing CMS for services, you may be MIPS eligible. Knowing if your practice and individual providers qualify under MIPS 2019 may have a large financial impact to providers and practices. Working with an organization that understands the MIPS framework and is technically enabled to collect and aggregate your data for submission will drive revenue back to the practice and make the whole MIPS 2019 process easier.
MIPS 2019 eligibility includes:
- Physicians (Doctors of medicine, osteopathy, dental surgery/medicine, podiatry, and optometry)
- Osteopathic practitioners
- Physician Assistants (PAs)
- Nurse Practioners (NPs)
- Clinical Nurse Specialists (CNSs)
- Certified Registered Nurse Anesthetists (CRNAs)
- Physician and Occupational Therapists (PTs/OTs)
- Clinical Psychologists
- Qualified Speech-language Pathologists
- Qualified Audiologists
- Registered Dietitians or Nutritional Professionals
For eligible MIPS 2019 clinicians, the real challenge is understanding thresholds and exemptions to make sure you need to report in 2019.
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 individual NPI but billing under a new Tax Identification Number (TIN) 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.
The low-volume threshold has been updated with a 3rd criteria under MIPS 2019. Below are the criteria establishing eligibility for the 2019 reporting year:
- Bill more than $90,000 in Medicare part B allowed charges for covered professional serviced payable under the Physician Fee Schedule (PFS), and
- Provide covered professional services for more than 200 Part B beneficiaries, and
- Provide more than 200 covered professional services to Part B beneficiaries.
Check your eligibility at the CMS Quality Payment Program website, HERE.