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With all the uncertainty in healthcare today, there’s one thing that’s certain: the Centers for Medicare & Medicaid Services’ (CMS’) implementation of the Quality Payment Program (QPP) through the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).
The QPP is a huge shift in payment for healthcare providers that places significant revenue at stake and pays based on performance. It has two primary payment tracks for clinicians to choose from – the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs).
MIPS affects a specific group of clinicians beginning in 2017 and then branches out to include additional clinicians in 2019. In this track, providers remain in fee-for-service under Medicare but become eligible for either bonus payments or penalties based on their performance in the QPP.
For providers choosing MIPS, there are a few timely elements to consider. For instance, the 2017 measurement period is a transition year. During this transition, it can be difficult to parse out who is eligible to participate, who is excluded and who qualifies for alternate scoring in MIPS.
Below are some key considerations for determining who must report for MIPS in 2017, and who will face the subsequent performance-based payment adjustments in 2019.
Clinicians required to participate in MIPS are defined as “eligible clinicians” (ECs).
For the 2017 performance period (impacting 2019 payments), the list includes:
Note that while the term “eligible” is used, failure to participate when deemed an EC will result in an automatic downward payment adjustment on every Medicare Part B claim two years in the future.
Though other clinicians are not eligible to participate in 2017, beginning in 2019 (impacting 2020 payments) the list of ECs will expand to include:
Some of the current ECs are excluded from reporting MIPS in 2017. This includes:
The following current ECs qualify for alternate scoring in 2017.
Now that you understand if you’re required to report for MIPS in 2017, learn more about MIPS reporting in my next post, or CLICK HERE for more information.