MIPS: Can I Ignore or Avoid It?

Leigh Page


July 07, 2016

In This Article

Reducing or Eliminating Your Participation in MIPS

The Merit-Based Incentive Payment System (MIPS), which is replacing the sustainable growth rate formula, has its share of fans. But there are also a large number of physicians with a wait-and-see attitude, and many physicians are questioning whether they can just opt out—but without leaving Medicare. That's in addition to wondering whether they will earn more or less with MIPS.

There is a way to reduce your MIPS reporting burden: You and your group of clinicians can report together in single submission. "It would be administratively simple to report as a group," says Tom S. Lee, PhD, founder and CEO of SA Ignite, a Chicago company that helps organizations manage value-based programs. A large practice or group of hospital-employed physicians is likely to have the staff and IT capabilities to centralize reporting, he says.

The Centers for Medicare & Medicaid Services (CMS) defines a group as having at least two "eligible clinicians," who could be a physician and a nurse practitioner or physician assistant in one practice. This leaves out strictly solo clinicians. However, even small practices might not have the infrastructure to report as a group. In the proposed rule, CMS said it plans to allow solo and small practices to get together in "virtual groups," but owing to the difficulties of implementing such arrangements, this won't be possible in the first year of MIPS reporting.

The downside of reporting in a group is that "you would have limited ability to choose specific measures," Dr Lee says. "You may be forced to accept measures for activities where you don't perform that well." Also, all measures would have to be reported as a group. The proposed rule states, "If a group submits data for the quality performance category as a group, CMS would assess them as a group for the remaining three performance categories."

A Temporary Exemption

In addition to allowing centralized reporting, the proposed rule offers some full exemptions from MIPS. Physicians in the first year of Medicare would be exempted—but of course, this only lasts 1 year.

On the other hand, clinicians could get a perpetual exemption if they have small Medicare volume, defined in the proposed rule as less than $10,000 in allowable claims a year and fewer than 100 Medicare patients. In the document, CMS estimated that 225,615 clinicians would use this exemption—a far greater number than those who would be exempted through advanced alternative payment models (APMs).


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