Calculation of the low-volume threshold – MIPS participation eligibility is determined through a calculation of annual Medicare Part B allowable charges. In 2018, ECs and groups must submit at least $90,000 annually and care for at least 200 Medicare beneficiaries annually to be eligible for a positive or negative payment adjustment based on performance. With the enactment of the Bipartisan Budget Act, Medicare Part B medications and services billed separately from the Physician Fee Schedule will no longer be included in the low-volume threshold calculation. For many specialists and small practice clinicians, this will likely result in their exclusion from the program for the 2018 performance year. If you are unsure of your eligibility, check the QPP participation look-up tool – https://qpp.cms.gov/participation-lookup, which will be updated with the new calculation in March 2018.

Flexibility to determine the MIPS performance threshold – MACRA also specified that by the 2019 MIPS performance year, the performance threshold needed to avoid a payment penalty was to be set at the average MIPS performance score. With the MIPS performance scores being entirely unknown for 2017 performance year, this increase would likely mean that a significant number of ECs and groups would not meet the threshold and would receive a negative payment adjustment of 7% or more, depending on program year. The Bipartisan Budget Act will enable CMS to have more flexibility in determining a gradually increasing performance threshold through 2021. This increased flexibility will provide ECs and groups with the ability to more effectively develop quality improvement and reporting strategies to meet the requirements of MIPS.

Still working on your 2017 MIPS data submission? The deadline for submission is March 31st, 2018 to avoid a 5% negative payment adjustment on your 2019 Medicare Part B claims. Need assistance? Contact the New England QIN-QIO for no-cost personalized assistance.