Are You Exempt From MIPS in 2018?

There’s possibly more to be thankful for this November: You just might be exempt from MIPS next year under the newly released final rule for the 2018 Quality Payment Program (QPP).

You read that right. See, an increase in the low-volume threshold will make an estimated 63 percent of clinicians who bill Medicare exempt from the Merit-Based Incentive Payment System (MIPS) next year, according to the Centers for Medicare & Medicaid Services (CMS).

You got to like those odds. But that’s not all. There are quite a few changes to the final rule, which CMS released this month as required by the Medicare Access and CHIP Reauthorization Act (MACRA). 

The 2018 QPP rule covers both MIPS fee-for-service payments and the Alternative Payment Model (APM) programs — both of which could boost or cut your Medicare payments in 2020. 

TMA submitted formal comments on the rule in August. A preliminary review by TMA staff experts shows that CMS accepted several of our 50-plus recommendations. 

Major policy changes include: 

  • The new low-volume threshold for 2018 would exclude physicians and other eligible clinicians with $90,000 or less in Medicare Part B allowed charges, or 200 or fewer Medicare Part B beneficiaries — this is up from $30,000 or 100 in 2017. (TMA supported an increase to the low-volume threshold.)
  • Physicians still can use the 2014 or 2015 electronic health record (EHR) edition or a combination to meet requirements for the advancing care information category. CMS also will add a hardship exception to this category for small practices. (TMA supported these policies.)
  • Texas physicians in Hurricane Harvey disaster-designated areas can be exempt from the 2017 MIPS performance period without submitting a hardship exception application. (In a separate formal letter in September, TMA had asked that physicians in those areas be given the option to be exempt from MIPS.)
  • Beginning in 2019, physicians could become Qualified APM Participants through some arrangements with non-Medicare, Other Payer Advanced APMs such as Medicaid APMs and Medicaid Medical Home Models, as well as other models described in the regulations.  

For more information and a comparison of 2017 and 2018 policies, refer to the CMS fact sheet and executive summary

Visit the TMA MACRA Resource Center to keep up with the latest information. If you don’t know where to start, review this TMA article for guidance on how to master the QPP and where to get help. To learn about 2018 QPP requirements and options, sign up for upcoming webinars on the CMS website

Also, take advantage of TMA’s Medicare and MACRA seminars underway now at multiple locations throughout the state. To reserve your spot, register for an upcoming live event at a city near you or register to participate in the live webcast on Dec. 7. 

Action, Nov. 15, 2017

Published On

November 15, 2017

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