CMS to Mail Merit-based Incentive Payment System (MIPS) Letters Now through May

By David White

ASN is carefully monitoring the notification process and wants to hear from you.

Please email Kidney News staff at info@kidneynews.org to express your opinions and comments so that we may assist you through this process.

Keep a lookout in your mail this week and through early May. The Centers for Medicare & Medicaid Services (CMS) is mailing out Merit-based Incentive Payment System (MIPS) “participation status” letters to several hundred thousand clinicians who participate in Medicare., according to CMS officials who spoke this week on a National Stakeholders conference call, in which ASN participated. The mailing is to notify you, other clinicians, and practices of their MIPS status. This status tells you, or other clinicians in your practice, if any of you will be required to participate in MIPS in 2017. 

MIPS is a central component of the Quality Payment Program (QPP) created by Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). More information on the mailing, MIPS, and the QPP are on the ASN website.

"This letter will tell the participation status of each MIPS clinician associated with the Taxpayer Identification Number or TIN in a practice," CMS said. Due to the use of TINs, ASN is concerned some clinicians may receive multiple notices or none leading to possible confusion. However, CMS said clinicians should participate in MIPS for the 2017 transition year if they bill more than $30,000 in Medicare Part B allowed charges a year, and provide care for more than 100 Part B-enrolled Medicare beneficiaries a year. 

"The Quality Payment Program intends to shift reimbursement from the volume of services provided toward a payment system that rewards clinicians for their overall work in delivering the best care for patients... During this first year of the program CMS is committed to diligently working with you to streamline the process as much as possible."  

The final regulations for the QPP exempted between 53% and 57% of physicians and other clinicians from a potential 2019 penalty under the MIPS reimbursement system, because many of these were either new clinicians or ones who participated in advanced alternative payment models and were therefore exempt from MIPS. But 32.5% of clinicians who take Medicare, according to CMS, are excluded from MIPS because they don't have at least $30,000 in annual Medicare revenues.

CMS maintains that if a clinician is unclear whether he or she is eligible for MIPS, that clinician could choose the minimum option under CMS' "pick your pace" approach. By simply reporting on a single quality or practice improvement measure, the clinician could avoid a penalty in 2019.

The letters will come from Medicare Administrative Contractors that process Medicare Part B claims. The first (transition) year for the QPP began January 1, 2017 and has a “Pick Your Pace” reporting formula that allows clinicians to pick the level of reporting that best suits them for 2017. Participants have until October 2, 2017 to decide and until March 31, 2018 to report their data.

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ASN is carefully monitoring the notification process and wants to hear from you.

Please email Kidney News staff at info@kidneynews.org to express your opinions and comments so that we may assist you through this process.

Keep a lookout in your mail this week and through early May. The Centers for Medicare & Medicaid Services (CMS) is mailing out Merit-based Incentive Payment System (MIPS) “participation status” letters to several hundred thousand clinicians who participate in Medicare., according to CMS officials who spoke this week on a National Stakeholders conference call, in which ASN participated. The mailing is to notify you, other clinicians, and practices of their MIPS status. This status tells you, or other clinicians in your practice, if any of you will be required to participate in MIPS in 2017. 

MIPS is a central component of the Quality Payment Program (QPP) created by Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). More information on the mailing, MIPS, and the QPP are on the ASN website.

"This letter will tell the participation status of each MIPS clinician associated with the Taxpayer Identification Number or TIN in a practice," CMS said. Due to the use of TINs, ASN is concerned some clinicians may receive multiple notices or none leading to possible confusion. However, CMS said clinicians should participate in MIPS for the 2017 transition year if they bill more than $30,000 in Medicare Part B allowed charges a year, and provide care for more than 100 Part B-enrolled Medicare beneficiaries a year. 

"The Quality Payment Program intends to shift reimbursement from the volume of services provided toward a payment system that rewards clinicians for their overall work in delivering the best care for patients... During this first year of the program CMS is committed to diligently working with you to streamline the process as much as possible."  

The final regulations for the QPP exempted between 53% and 57% of physicians and other clinicians from a potential 2019 penalty under the MIPS reimbursement system, because many of these were either new clinicians or ones who participated in advanced alternative payment models and were therefore exempt from MIPS. But 32.5% of clinicians who take Medicare, according to CMS, are excluded from MIPS because they don't have at least $30,000 in annual Medicare revenues.

CMS maintains that if a clinician is unclear whether he or she is eligible for MIPS, that clinician could choose the minimum option under CMS' "pick your pace" approach. By simply reporting on a single quality or practice improvement measure, the clinician could avoid a penalty in 2019.

The letters will come from Medicare Administrative Contractors that process Medicare Part B claims. The first (transition) year for the QPP began January 1, 2017 and has a “Pick Your Pace” reporting formula that allows clinicians to pick the level of reporting that best suits them for 2017. Participants have until October 2, 2017 to decide and until March 31, 2018 to report their data.