Posted on December 6, 2018
Clinicians should verify if they are required to report MIPS for 2018 by checking their status on the CMS QPP Participation Status Tool website. CMS recently updated the tool based on its most recent MIPS eligibility status review of clinician eligibility. If clinicians bill under multiple practices/Tax Identification Numbers (TINs), the tool indicates whether or not they must participate under each practice. The tool also indicates a clinician’s participation status in a Qualifying APM and if the provider has a special status designation for which special rules may apply (e.g., hospital-based, patient-facing and small practice).
CMS MIPS Status Review Periods
CMS reviewed clinician eligibility for 2018 at 2 different times during the performance year:
- The initial 2018 MIPS eligibility status was based on the CMS review of Medicare Part B claims and PECOS data from September 1, 2016, to August 31, 2017.
- The second review was based on Medicare Part B claims and PECOS data from September 1, 2017, to August 31, 2018.
What does this mean to you?
CMS is encouraging clinicians to confirm their final 2018 MIPS eligibility in case there were any changes based on the second review. CMS stated that if, after the first review earlier this year, they were determined to be:
- Eligible for MIPS: Eligibility status might change, and they might no longer be eligible for MIPS (e.g., not required to report MIPS in 2018).
- Not eligible for MIPS at a particular practice: Eligibility status, based on association with that particular practice, will not change.
IMPORTANT: If a clinician joined a new practice/TIN between September 1, 2017, and August 31, 2018, CMS evaluated MIPS eligibility based on the association with that new practice during this second review. This means the clinician may be required to report MIPS for the new practice/TIN.
CMS has said that if a clinician joined a new practice after August 31, 2018, he /she is not eligible for MIPS as an individual based on his / her association with that new practice/TIN. However, if the new practice the clinician joined chooses to participate in MIPS as a group, the clinician may be eligible to receive a MIPS payment adjustment based on the group’s participation.
Who is MIPS Eligible for 2018?
There are several “types” of providers that are considered “MIPS eligible clinicians” and are included in the program in 2018 if they bill Medicare Part B claims:
- Physicians (including doctors of medicine, doctors of osteopathy [including osteopathic practitioners], doctors of dental surgery, doctors of dental medicine, doctors of podiatric medicine, doctors of optometry, and doctors of chiropractic)
- Physician assistants
- Nurse practitioners
- Clinical nurse specialists
- Certified registered nurse anesthetists
Some clinician “types” are excluded from MIPS reporting in 2018:
- Physical or occupational therapists
- Speech-language pathologists
- Nurse midwives
- Clinical social workers
- Clinical psychologists
- Dieticians/nutritional professionals.
IMPORTANT: CMS has expanded the definition of MIPS eligible clinicians for the 2019 performance year to include the following additional clinician types next year:
- Physical therapists
- Occupational therapists
- Qualified speech-language pathologists
- Qualified audiologists
- Clinical psychologists
- Registered dietitian or nutrition professionals
For more information on the 2019 reporting requirements, click here.
MIPS Exemptions for 2018
For 2018, CMS is excluding the following categories of clinicians from the MIPS reporting requirements:
- Clinicians who enroll in Medicare for the first time in 2018
- Clinicians who participate in an Advanced APM and are either a Qualifying APM Participant (QP) or a Partial QP
- Clinicians who are not in a MIPS eligible specialty (e.g., PT, OT, social worker, etc.)
- Clinicians who meet the low volume threshold:
- Clinicians who bill for $90,000 or less in Medicare Part B allowed charges for covered professional services during either of the two determination periods; OR
- Clinicians who have provided covered professional services for 200 or less Medicare Part B-enrolled patients during either of the two review periods.
We have heard from clinicians who are not MIPS eligible for 2018, but still want to report MIPS this year to maintain reporting practice and to stay on top of the CMS requirements. Clinicians who are not MIPS eligible have the option to report on a voluntary basis this year. Individual clinicians reporting on a voluntary basis would not be subject to any payment adjustment for the 2018 performance year.
In addition, next year CMS will allow clinicians who are not MIPS eligible, but meet certain criteria, to “opt in” to the program for the 2019 performance year. Clinicians choosing to “opt-in” to the program in 2019 would be subject to upward or downward payment adjustments, depending on their final MIPS score.
Clinicians should check their MIPS participation status as soon as possible to determine if they are required to report MIPS this year. If they are a MIPS eligible clinician, they need to achieve at least 15 MIPS points to avoid the automatic 5% penalty in 2020. And, if they determine that they are not required to report this year, they can still do so on a voluntary basis.
MDinteractive makes reporting easy, so visit our website to view your reporting options with our registry. Our MIPS specialists are standing by to answer any questions about your MIPS participation status, or help you get started with your reporting.
MACRA MIPS MIPS Eligibility MIPS Participation Status MIPS Eligible Clinicians