Are You Exempt From MIPS In 2017?

If 2017 is a provider’s first year enrolled as a Medicare provider, he or she is exempt from Merit-based Incentive Payment System (MIPS) participation in 2017. Providers are also exempt from participating in MIPS in 2017 if they are significantly participating in an advanced Alternative Payment Model (APM) as qualified providers or participating in certain, partially qualifying APMs. There are expected to be very few and quite possibly zero podiatrists who will meet this exemption.

There are also volume thresholds, which, if not reached, can lead to exemption. If providers have less than $30,000 in Medicare Part B allowable or see fewer than 100 Part B-enrolled Medicare beneficiaries within a designated one-year time period, they are exempt from participation in 2017. These two one-year periods are between Sept. 1, 2015 and Aug. 31, 2016, and between Sept. 1, 2016 and Aug. 31, 2017.

The Centers for Medicare and Medicaid Services (CMS) are currently reviewing claims to determine which clinicians will be exempt from participating in MIPS based on the aforementioned volume thresholds. The CMS has announced that sometime during the month of May 2017, each of us will receive a letter from the Medicare Administrative Contractor that processes our Medicare Part B claims and this letter will indicate whether we are exempt from the MIPS program for 2017, or whether we need to participate in order to avoid a penalty. Those who are exempt will not be assigned any 2017 MIPS score and will not see any adjustment, positive or negative, to their 2019 Medicare Part B Physician Fee Schedule.

Dr. Lehrman is on the APMA Coding Committee, serves as an expert panelist on Codingline and is a Fellow of the American Academy of Podiatric Practice Management (AAPPM). Follow him on Twitter @DrLehrman .

Reference

1. Centers for Medicare and Medicaid Services. Mlnconnects. Available at https://www.cms.gov/Outreach-and-Education/Outreach/FFSProvPartProg/Provider-Partnership-Email-Archive-Items/2017-04-27-eNews.html?DLPage=1&DLEntries=10&DLSort=0&DLSortDir=descending#_Toc480950472 . Published April 27, 2017.