CMS Eases Eligibility Threshold Again on MIPS Participation

The Centers for Medicare and Medicaid Services (CMS) announced today that they intend to further raise the threshold for participation in its Merit-Based Incentive Payment System (MIPS). In its much-anticipated proposed 2018 rule for the Quality Payment Program (QPP), CMSproposed to increase the threshold to exclude MIPS-eligible clinicians or groups with $90,000 or less in Part B-allowed Medicare charges or 200 or fewer Part B Medicare beneficiaries.

The threshold applies to the 2018 performance year.  The current thresholds will remain for 2017.  In the 2017 performance year, which determines payment adjustments in 2019, individual  Merit-Based Incentive Payment System -eligible clinicians or groups with $30,000 or less in Part B-allowed charges or 100 or fewer beneficiaries are exempted from MIPS.

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CMS announced that the 2018 QPP proposal represents CMS’ plan to lighten the burden of MIPS on physicians while making it easier for them to join advanced alternative payment models that pay bonuses and exempt them from MIPS.

Among other things, the QPP proposal:

• Offers practices of 10 or fewer clinicians the option to participate in a “virtual group” that can help small practices with performance reporting
• Allows clinicians to continue using 2014-edition certified electronic health record technology (CEHRT) while encouraging the use of 2015 edition CEHRT
• Adds bonus points in the scoring methodology for clinicians who care for complex patients or who use 2015-edition CEHRT exclusively
• Incorporates MIPS performance improvement in quality scores
• Incorporates the option to use facility-based scoring for facility-based clinicians

CMS is also proposing more flexibility for clinicians in small practices. Under the QPP proposal, the agency would do the following:

• Add a new hardship exception for clinicians in small practices under the Advancing Care Information performance category
• Add bonus points to the final score of clinicians in small practices
• Continue to award small practices three points for measures in the quality performance category that don’t meet data completeness requirements

In addition, CMS announced that they will allow physicians to use their 2014-edition EHRs for another year. Previously, they were supposed to start using the 2015-edition versions for  Merit-Based Incentive Payment System reporting by January 1, although CMS previously adopted a 90-day reporting period for Advancing Health Information, the successor to meaningful use.

Comments on the proposed rule are due by August 30.