News & Insights

CMS MIPS Eligibility Letters in the Mail

May 10, 2017

CMS MIPS Eligibility Letters in the Mail

The Centers for Medicare & Medicaid Services (CMS) is currently sending out Merit-Based Incentive Payment System (MIPS) eligibility letters to all Medicare Part B providers detailing their eligibility. Providers in Louisiana, Arkansas, Mississippi and Texas should expect letters to arrive from Novitas Solutions, the Medicare Administrative Contractor for these states. Eligible clinicians who do NOT report any data in 2017 will be subject to a 4% penalty on all Part B fees in 2019.  

Providers will receive letters for each Tax ID under which they bill, and the eligibility may be different for each Tax ID.

In addition to these hard copy notices, clinicians can now use an interactive tool on the front page of the CMS Quality Payment Program website to determine if they should participate in 2017.

Providers who are not deemed to be eligible clinicians will not be subject to the positive or negative adjustments in 2019 and are not required to submit data to CMS for this performance year.

QPP Eligibility

CMS defines MIPS-eligible providers as:
•    M.D., D.O., DDS, DDM, DPM, OD, Chiropractor, PA, NP, CNS and CRNA
•    Not new to Medicare (participated in Medicare before 2017)
•    Have more than $30K in Medicare Part B allowable charges AND have more than 100 Medicare Part B patients
•    Not a qualified participant in an AAPM

If you believe the information in the letter (on Attachment A) or on the CMS online tool is incorrect, or if you do not receive a letter at all, please contact the Quality Payment Program at qpp@cms.hhs.gov or 866.288.8292.

QPP Background

QPP Defined

  1. The Quality Payment Program (QPP) was created with the MACRA (Medicare Access and CHIP Re-authorization Act) legislation that passed with bipartisan support
  2. QPP consolidates the quality programs previously in existence and rolls them into one
    • Physician Quality Reporting System (PQRS)  
    • M eaningful Use (MU)
    • Value-Based Modifier (VBM)
  3. The first QPP participation year began January 1, 2017 for Medicare Part B providers
  4. QPP has two tracks:  
    • Advanced Alternative Payment Models (AAPM) 
    • Merit-Based Incentive Program (MIPS) 
      • Most providers in 2017 will follow the MIPS pathway
  5. MIPS includes the following performance categories:
    • Quality – A revision of PQRS
    • Advancing Care Information – A revision of MU
    • Improvement Activities – A new category tracking focused on improving patient engagement and satisfaction
    • Cost – will not be factored into the score in 2017

2017 Options for MIPS Participation

Providers have 4 options for 2017 reporting through the Pick Your Pace Program. All data must be submitted to CMS no later than March 31, 2018.

  1. Submit minimal data (Test Pace) to avoid a penalty by submitting 1 quality measure on 1 patient, OR meet the base measures for Advancing Care Information Measures (ACI) performance, OR attest to an Improvement Activity for 30 days.
  2. Submit 90 days worth of data in Quality AND Improvement Activites AND meet the base measures in ACI to avoid a penalty and possibly earn a positive payment adjustment of up to 4% on 2019 payments.
  3. Submit 6 Quality measures, 4 Improvement activities AND meet ACI Base and performance measures for at least 90 days to avoid a penalty possibly earn a positive payment adjustment AND a bonus in 2019.
  4. Do not submit any data and will be penalized in 2019 with a 4% negative payment adjustment.

QPP Reporting

Eligible clinicians can report either as a group (multiple NPIs linked to 1 Tax ID) or as an individual (1 NPI linked to 1 Tax ID). However, a clinician must report as a group or as an individual across all 3 categories.

Providers can submit data to CMS in various ways:

  • Certified EHR Technology (EHR)*
  • Qualified Registry (QR)* 
  • Qualified Clinical Data Registry (QCDR)* 
  • Claims**
  • Administrative Claims ***
  • Attestation via CMS
  • CAHPS for MIPS Survey****
  • For groups over 25, CMS Web Interface (GPRO)**** 

    * Can be used regardless of group or individual status and across all performance categories
    **Can only be used to report Quality for providers reporting as individuals
    ***Does not require any intervention by 
provider. Is only available for Cost and Quality - All Cause Readmission Rate.
    **** Must register by June 30, 2017

A different submission method can be employed for each performance category, but clinicians must report as either an individual or a group across all categories.

There are costs and benefits to each method of reporting.

Please contact LAMMICO’s Practice Management Specialist, Natalie Cohen, MBA, MHA at 504.841.2727 or ncohen@lammico.com if you have any questions about QPP, need clarification or additional information.

                                

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