TIP: Verify Your MIPS Participation Status and Understand the Impact on Group Scoring

CMS is currently notifying physicians who participate in Medicare whether they fall under the “low volume threshold” and thus exempt from the Merit-Based Incentive Payment System (MIPS) in 2017. CMS defines low volume as less than $30,000 in allowed Part B charges or 100 or fewer Medicare patients seen in the year. All physicians will receive a letter at the TIN level notifying them of their status. Physicians and practices are also able to use CMS’ web look-up tool to determine individual physicians’ eligibility.  While most ASCRS members are expected to be well above the threshold, and thus required to participate in MIPS, it is important to understand how physicians under the low volume threshold may impact group scoring. If a low volume physician bills under a TIN that is reporting MIPS as a group, then his or her performance will be included in the group’s score and will receive the same payment adjustment. While the MIPS payment adjustment will only affect Medicare Part B reimbursements, a low volume provider’s score calculations will not be based solely on his or her encounters with Part B patients. Like other physicians who participate in MIPS, a low volume physician in a group participating in MIPS is subject to the same reporting requirements: quality measures submitted through EHR or registry must be reported on at least 50% of all patients from all payers and all patients are included in Advancing Care Information measure calculations. For example, if a practice has a pediatric ophthalmologist who is determined to be under the low volume threshold and the practice elects to report as a group through IRIS, all of his or her encounters become eligible for MIPS scoring. Consider how reporting on a low volume provider’s total patient population may impact your group’s MIPS performance.