April 28, 2017

CMS Notifies Clinicians About MIPS Exemptions

The Centers for Medicare and Medicaid Services (CMS) announced April 24 it has begun disseminating letters notifying clinicians whether they are exempt from participating in the Merit-Based Incentive Payment System (MIPS). Exemption will be based on whether practices or individual clinicians fall below the low-volume threshold of billing less than or equal to $30,000 Medicare of allowable Part B charges or if they provide care for 100 or fewer Medicare beneficiaries.

The notification letters will be distributed through the end of April and first week of May by the Medicare Administrative Contractor (MAC) that processes Medicare Part B claims to the clinician’s associated group Taxpayer Identification Number (TIN). The letter will specify the participation status of each MIPS clinician associated with the TIN in a practice. Clinicians will receive status notification letters for each TIN they participate.

The American College of Radiology was disappointed to learn that special status, such as hospital-based and non-patient facing determinations, will not be disclosed in the letters. This decision will make it difficult for radiologists, who are considered non-patient facing or hospital-based, to know how many improvement activities they must report and whether the Advancing Care Improvement (ACI) category will be reweighted to zero.

CMS does not plan to send any letters on special status. It asserts that physicians can instead make this determination by using the CMS portal that will be available on its Quality Payment Program (QPP) website. However, CMS is still working on developing the portal and has not indicated when it will be available publicly.

The ACR will contact CMS to address these concerns and will notify ACR members of any updates. For more information, refer to the Quality Payment Program website.