CMS Notifies Physician Practices of MIPS Participation

As mandated by the Medicare Access and CHIP Reauthorization Act's Final Rule, the Centers for Medicare & Medicaid Services (CMS) is starting to notify physicians and other clinicians if they need to participate in the Merit-based Incentive Payment System (MIPS). In general, under MACRA, clinicians who are newly enrolled in Medicare, participate in certain Advanced Alternative Payment Models, bill less than $30,000 in Medicare Part B allowed charges a year,or provide care for less than 100 Part B-enrolled Medicare beneficiaries a year are excluded from participating in MIPS. Practices are starting to receive letters from their Medicare Administrative Contractor (MAC) giving the status for each clinician associated with the Taxpayer Identification Number (TIN).

The first part of these letters look and read as follows:

The letter is accompanied by an Attachment A, which is a list of each clinician, listed by provider number, associated with the TIN that identifies his or her eligibility, along the lines of the following:

Practices must decide if they are participating in MIPS as a group or if its clinicians will be participating on an individual basis. In the latter event, the practice should let each clinician associated with its TIN know whether they are excluded or included in MIPS. If included, the clinician will need to collect performance data around three areas, as described in greater detail at CMS Quality Payment Program website, and submit the same no later than March 31, 2018 to avoid negative payment adjustments of up to 4% affecting 2019 Medicare Part B payments.

For further information on MACRA preparedness, please contact Sidney Welch, Bruce Johnson, Cybil Roehrenbeck, or Neal Shah with Polsinelli's Health Care Innovation Practice.