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Are you subject to MIPS reporting requirements in 2017?

Christina Randolph June 13, 2017

The Centers for Medicare and Medicaid Services (“CMS”) announced in late April that they anticipated notifying eligible clinicians about their Merit-based Incentive Payment System (“MIPS”) participation status for 2017 via letter sometime in May. The letter would come from the Medicare administrative contractor who processes the Medicare Part B claims for the particular clinician or group of clinicians.

Once the letters were disseminated, Modern Healthcare reported that more than 800,000 clinicians were notified they would be exempt from complying with MIPS requirements in 2017. These clinicians include those in their first year of Medicare Part B participation in 2017, as well as those that fall below the low patient volume threshold (that is, those with Medicare Part-B billing charges less than or equal to $30,000 OR provide care for 100 or fewer Medicare Part-B patients in one year).

Under MIPS, Medicare reimbursement payments will be based on a combination of quality measures and use of electronic health records. Based on these metrics, physicians can receive a bonus or penalty of 4% of their reimbursement in 2019.

If you are a provider who is still unsure whether you need to participate in MIPS in 2017, you can check your exemption status online. CMS still encourages exempt clinicians to voluntarily submit data this year to familiarize themselves with the process. Those who submit data voluntarily will not be subject to a payment adjustment.

For more information, please see CMS’s MIPS Participation Fact Sheet.

Christina Randolph is a partner in Thompson Coburn's health care practice. Special thanks to summer associate Lauren Pair for her assistance.