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2019 MIPS Eligibility

Who Participates in MIPS?

You are eligible to participate in the MIPS track of the Quality Payment Program if you bill more than $90,000 to Medicare in allowable charges, AND provide care to more than 200 Medicare patients per year, AND cover more than 200 professional services during the performance period,and you are one of the following clinicians:

  • Physicians, which includes doctors of medicine, doctors of osteopathy (including osteopathic practitioners), doctors of dental surgery, doctors of dental medicine, doctors of podiatric medicine, doctors of optometry, and chiropractors
  • Physician assistants (PAs)
  • Nurse practitioners (NPs)
  • Clinical nurse specialists
  • Certified registered nurse anesthetists
  • Any clinician group that includes one of the professionals listed above
  • Clinical Psychologists
  • Physical Therapists
  • Occupational Therapists
  • Speech-Language Pathologists
  • Audiologists
  • Registered Dieticians

Determine Your MIPS Eligibility

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What Should You Do?

If included in MIPS, the clinician:

  • Must participate to avoid a negative adjustment to their Medicare Part B payments and potentially earn an upward adjustment.
  • Can participate as an individual or as part of their group.
  • Collect performance data for services that were furnished beginning on January 1, 2019 until December 31, 2019.

Performance Determination

For the 2019 MIPS performance period and the 2021 MIPS payment year, CMS will make low-volume status determinations based on satisfying either low-volume threshold in either one of the following evaluation periods:

  • Historical claims data: October 1, 2017 – September 31, 2018
  • Performance period claims data: October 1, 2018 – September 31, 2019

Exemptions

For the CY 2019 performance year, there are three exemptions from MIPS for clinicians who otherwise meet the eligibility requirements above:

  • Clinicians in their first year of Medicare Part B participation
  • Clinicians billing Medicare Part B up to $90,000 in allowable charges or providing care for up to 200 Part B patients and covering up to 200 professional services in one year
  • Clinicians in entities sufficiently participating in an Advanced APM for which either:
    • You receive 50% of your Medicare Part B payments through an Advanced APM or
    • See 35% of your Medicare patients through an Advanced APM

Voluntary Participation for Non-Eligible MIPS Clinicians

Clinicians who are not included in MIPS for the 2019 reporting year, may choose to voluntarily submit data individually to CMS to learn, obtain feedback on quality measures, and prepare in the event MIPS is expanded in the future. Clinicians who submit data voluntarily will not be subject to a positive or negative payment adjustment.

Can Choose to Opt-In (Newly Added for Year 3):

  • Opt-In Policy is available for MIPS eligible clinicians who are excluded from MIPS based on the low-volume threshold determination
  • If you are a MIPS eligible clinician and meet or exceed at least one, but not all, of the low-volume threshold criteria you may opt-in
  • If you opt-in, you’ll be subject to the MIPS performance requirements, MIPS payment adjustments, etc.
  • Once an election has been made, the decision to opt-in to MIPS would be irrevocable and could not be changed

 

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