FAQs

Physicians and other clinicians can check their MIPS eligibility.

Anesthesiologists and other clinicians who bill Medicare Part B must participate and will be subject to a penalty unless they qualify for one of the following exemptions:

1. Low volume threshold. This is defined as clinicians with less than or equal to $30,000 in allowed charges or less than or equal to 100 Medicare patients.
2. Clinicians participating as a QP in Advanced APMs are exempted from reporting MIPS.
3. Clinicians in their first year of Medicare Part B participation.

CMS has implemented a “Pick Your Pace” plan for 2017. For the 2017 transitional year, only those ECs who do not submit any data to CMS will be subject to the -4 percent payment adjustment. Submission of data will allow an EC to obtain a neutral or positive payment adjustment.

1. Test - If an EC submits one quality measure, one IA, or ACI measures, the EC will avoid the negative adjustment. The EC will not be eligible for a positive adjustment.
2. Partial – If an EC submits 90 days of data on more than one quality measure, more than one IA, or more than the required ACI measures, s/he will avoid the negative adjustment and may be eligible for a small positive adjustment.
3. Full – If an EC submits a full year of data on more than one quality measure, more than one IA, and the required ACI measures, s/he will avoid the negative payment adjustment and may be eligible for a modest positive payment adjustment. 
4. The fourth option for MIPS-eligible clinicians is to join an Advanced APM and become Qualifying APM Participants (QPs).

Please note, the “Pick Your Pace” plan is only for the 2017 performance year.

In 2017, MIPS-eligible clinicians must report for a minimum of 90 days to be eligible to receive an incentive.

MIPS eligible clinicians can choose to be assessed individually identified by their NPI/tax identification number (TIN) or as a group, defined by their TIN. Please note that an EC’s final score may be impacted based on whether he or she reported individually or as a group

Individual: ECs reporting at the individual level will be assessed based upon their National Provider Identifier (NPI)/Tax Identification Number (TIN) combination. Payment adjustments are based on performance across all MIPS categories and will be applied to the individual EC’s Medicare Part B reimbursements in the correlating payment year. If a clinician does not meet the minimum threshold for MIPS they are exempt from reporting MIPS at the individual level. The low volume threshold for individuals is defined as clinicians with less than or equal to $30,000 in allowed charges or less than or equal to 100 Medicare patients.

Group: A practice can report as a group when two or more ECs reassign their billing rights to a single TIN. Groups are assessed collectively at the TIN level across all MIPS categories and payment adjustments will be applied across the group. To participate as a group, the group must report data for all clinicians, including those that would have been exempt as individuals. The low volume threshold for groups is defined as practices with less than or equal to $30,000 in allowed charges or less than or equal to 100 Medicare patients. If a practice chooses to report via group, then all clinicians in the group must report.

CMS has released additional information on Group Reporting.

Virtual group reporting will begin in the 2018 performance year and CMS will release guidance later this year.

Under the final rule, hospital-based MIPS eligible clinicians are those who furnish 75 percent or more of his or her covered professional services in sites identified with Place of Service Codes 21 (Inpatient Hospital), 22 (On campus outpatient hospital), or 23 (Emergency room). CMS will determine Hospital-Based status on an annual basis.

ECs can check their status on the MIPS Participation Status site.

CMS stated in the final rule that it plans to use claims with dates of service between September 1 of the calendar year 2 years preceding the performance period. For example, for the 2017 performance period, CMS will use the data available at the end of October 2016 for Medicare claims with dates of service between September 1, 2015 through August 31, 2016, to determine whether a MIPS eligible clinician is considered hospital-based. If this isn’t operationally feasible, CMS will use a 12-month period as close as practicable to September 1 of the calendar year 2 years preceding the performance period and August 31 of the calendar year preceding the performance period. The hospital-based ACI exemption will be re-evaluated each payment year.

ECs can check their status on the MIPS Participation Status site.

In order to achieve the highest possible scores, CMS is encouraging MIPS eligible clinicians to submit data on as many measures and activities as possible in the three required performance categories.

If you are reporting as an individual, you can report via attestation, a QCDR, a Qualified Registry or via your EHR. If you are engaging in group reporting, you may report under each of the previously listed options in addition to the CMS Web Interface for groups of 25 or more.

ASA has compiled a list of resources related to the implementation of electronic health records.

For the 2017 performance period MIPS eligible clinicians can use EHR technology certified to the 2014 Edition, a combination of both 2014 and 2015 Editions, or the 2015 Edition. In 2018 and beyond, eligible clinicians must use the 2015 Edition to receive credit for ACI.

Note: If a MIPS eligible clinician switches from 2014 Edition to 2015 Edition CEHRT during the performance period, the data collected for the base and performance score measures should be combined from both the 2014 and 2015 Edition of CEHRT.

The Office of the National Coordinator for Health Information Technology (ONC) has developed a comprehensive database of certified EHR technology. As more versions of 2015 CEHRT become available, ONC will update this resource for those seeking to make EHR purchasing decisions. For additional questions, ONC can be reached by e-mail or by phone at (202) 690-7151.

CMS has published a comprehensive list of APMs along with the final rule.