What is the MIPS Impact to Non-Participating Medicare Providers?

Statistics indicate that only about 3% of chiropractic physicians participated in the initial roll-out of MIPS (2017), and, with the new thresholds that exempt more providers in 2018, that number fell to 1%. However, some non-participating providers have asked how MIPS impacts their practice.

CMS has addressed this clearly in the 2018 rulemaking process. The law indicates that MIPS payment adjustments are to be applied to payments made to MIPS eligible clinicians. Therefore, for non-participating providers who do not accept assignment, CMS  says, “the MIPS payment adjustment does not apply for nonassigned claims for non-participating clinicians” because payments are not made to the clinician in those cases.  Although CMS has followed this practice unofficially in the first years of MIPS, they are making it official for 2019.

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If you are a non-participating provider AND accept assignment, then the MIPS adjustments would impact your office, because Medicare makes payments to you directly rather than the patient. However, you should see our video on Medicare non-par doctors accepting an assignment to make sure you are billing according to Medicare Guidelines.