So you’ve been trying to read up on this thing called MACRA. You know it is going to affect how your organization gets paid for services. You’ve heard that you or your organization could either get a penalty, or incentive payment adjustment. That’s big. The best way to avoid being penalized, and to get in on the incentive payments, is to get your MACRA game on by participating in the Merit-based Incentive Program Systems (MIPS). The first step on that path is to figure out if you are eligible to participate in MIPS.
Eligible Clinicians
You are an eligible clinician if you participate in Medicare Part B, bill more than $30,000/yr, and provide care for more than 100 Medicare patients a year, and are one of the following:
Physicians
Physician Assistants
Nurse Practitioners
Clinical Nurse Specialists
Certified Registered Nurse Anesthetists
If you are mostly a non-patient facing clinician, you may also be eligible to participate in MIPS. Here’s how to tell if you or your group are eligible:
You must exceed the low-volume threshold, by having 100 or more patient facing encounters in a period.
You must already be participating in Medicare – this cannot be the first period you are participating.
You are not a qualifying APM participant, or are a partial Qualifying Participant that elects not to report data to MIPS.
If you belong to a group, your group is considered non-patient facing, if more than 75% of NPIs billing under the group’s Tax ID number during a performance period are non-patient facing.
Other considerations: Reporting requirements
You also have to decide if you want to report as an Individual, or as part of your Group. Reporting requirements are different for Eligible Clinicians, Non-patient facing clinicians, and Non-patient facing groups. MIPS Reporting requirements will be among the topics in future posts – but if you want to read more about it now, go to the CMS.gov website.
Not all clinicians can participate in MIPS
Who is excluded/exempt:
Newly-enrolled in Medicare – If you enrolled in Medicare for the first time during a performance period, you are exempt until the following year.
Below the low-volume threshold – Your Medicare Part B charges are $30K or less per year, or you see 100 or fewer Medicare Part B patients a year.
Significantly participating in Advanced APMs – You receive 25% of your Medicare payments, or see 20% of your Medicare patients through an Advanced Alternative Payment Model (Advanced APM).
Some of you will be excluded – or exempt – from participating this year. If it is just because you are new to Medicare, then this is a great time to prepare for 2018. You can position yourself to get the best incentive payment, if that is your ambition.
Are you one of the eligible clinicians, or part of an eligible clinician group? If so, what do you have to do, and when? Much of the documentation out there sounds like a legal document. Makes sense, especially when it is. President Obama signed MACRA into law on April 16, 2015.
January 1, 2017 marked the beginning of the first transition year. In the next post of the MACRA series, I’ll talk about what you can do during the “transition year” to avoid a -4% payment adjustment in 2019. And how you can shoot for the highest payment incentive.
Till then, make sure to subscribe, so you don’t miss future updates to this series.
P.S.: Please comment below, and tell me what you thought of the post, and what you’d like to hear more about. Whether you have questions about MACRA, QPP or MIPS, or on a totally different topic, let me know below!
