CMS Exempts Two Thirds of Clinicians From MIPS

Ken Terry

May 12, 2017

The Centers for Medicare & Medicaid Services (CMS) has exempted about two thirds of physicians and other clinicians who provide care to Medicare beneficiaries from the Merit-based Incentive Payment System (MIPS), a pay-for-performance scheme that will determine part of physicians' Medicare payments, starting in 2019.

A CMS spokesman told Medscape Medical News, "CMS mailed approximately 280,000 letters to practices using the Taxpayer Identification Number (TIN). The letter includes the MIPS participation status of each clinician associated with that practice's TIN. In terms of the number of clinicians, 418,849 will receive notification that they are participating in MIPS. And 806,879 will be notified that they are not participating in MIPS."

In the final regulations for the Medicare Access and CHIP Reauthorization Act (MACRA) issued last October, CMS predicted that between 53% and 57% of Medicare providers would be exempt from MIPS. But when the letters went out to practices, CMS excluded 65% of them.

According to the CMS source, who asked not to be identified, CMS attributes the difference between the two estimates partly to the limited accuracy of the predictive analytics it used to derive the data in the MACRA final rule. In addition, the source noted, CMS used a different time frame for calculating eligibility based on Medicare claims data than the one cited in the final rule.

CMS was unable to extract the percentage of physicians exempt from MIPS from the clinician total. However, it seems unlikely that the percentage would be higher than that for clinicians as a whole.

CMS earlier estimated that 32.5% of clinicians who take Medicare are excluded from MIPS because they don't have at least $30,000 in annual Medicare revenues. In addition, CMS exempts clinicians who are new to Medicare or who earn a specified share of their income from advanced alternative payment models. These models include accountable care organizations that participate in Track 2 or 3 of the Medicare Shared Savings Program, patient-centered medical homes in CMS' Comprehensive Primary Care Plus program, and certain Medicare bundled-payment arrangements.

In addition to the notification letters that CMS recently sent out, the agency has also recently introduced an online lookup tool that enables clinicians to determine whether they have to participate in MIPS.

Participating clinicians have the option to report performance data as individuals or as part of a group. Under the "pick your pace" approach that CMS adopted for this transitional year, clinicians can submit a minimal amount of performance data to avoid a penalty in 2019. Alternatively, they can submit 90 days of data or a full year of data to earn potential bonuses.

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