Medicare Compliance & Reimbursement

Even if you don’t meet the threshold, you should still prepare for future MIPS adoption.

If you’ve been on the edge of your seat waiting for your MIPS status, the wait is over.

Lowdown: According to a recent CMS update, provider and practice reviews are underway to determine who’s on the hook for the Merit-Based Incentive Payment System (MIPS). “In late April through May, you will get a letter from your Medicare Administrative Contractor that processes Medicare Part B claims, providing the participation status of each MIPS clinician associated with your Taxpayer Identification Number (TIN),” said MLN Connects in its April 27, 2017 release.

Much provider speculation and consternation accompanies the release of the highly anticipated MIPS status releases (Medicare Compliance and Reimbursement, Vol. 43, No. 7). Many are frustrated because the first reporting quarter has come and gone, and providers on the edge of the requirements don’t know if they’re in or out.

The facts: CMS guidance is very specific about who can participate under the new system. If you bill Medicare Part B more than $30,000 in payments a year and see more than 100 Medicare Part B-enrolled patients annually, then you are required to report measures under MACRA. However, if you don’t meet the mandated threshold, you are exempt from reporting for 2017 and can avoid the 4 percent penalty to your reimbursements paid out in 2019.

But that doesn’t mean you shouldn’t prepare to be part of MIPS in the future.

“Even if clinicians are not MIPS eligible in the first year, they could wind up being eligible in following years,” warns attorney Sarah Warden, Esq., of Greenspoon Marder in Ft. Lauderdale, Fla. “So clinicians that are right on the line of eligibility should consider taking steps to become MIPS ready.”

What-if scenario: Most practices know if they fall within the requirements to report under MIPS. So, what if your books suggest you’re in the program, but the letter never comes? “Contacting your MAC is a good idea for those clinicians that do not get a letter and are concerned that they may be over the low volume threshold,” Warden suggests.

Follow-up: The old adage “lost in the mail” may apply here if your contact details are outdated with Medicare. “Physicians should also make sure that their Medicare enrollment information is up to date so that the letter is sent to the correct address,” advises Warden.

Resource: For a closer look at the MLN Connects release, visit  >www.cms.gov/Outreach-and-Education/Outreach/FFSProvPartProg/Provider-Partnership-Email-Archive-Items/2017-04-27-eNews.html?DLPage=1&DLEntries=10&DLSort=0&DLSortDir=descending#_Toc480950472.