Recent reports say that one-third of the ECs will be exempted from MIPS reporting, because these ECs fall below the “low volume threshold.” This means that those ECs who submit the claims to Medicare for hundred or less patients or in Medicare Part B allowed charges or who submit claims for 30,000 dollars are free from the MIPS reporting and payment adjustments. What’s more, CMS is even planning to increase the patient encounter threshold for non-patient facing provider exemption from twenty-five or less encounters to hundred or less encounters.
Eligible Clinicians, who meet a participation threshold in the Advanced APMs, will also be exempted from the MIPS reporting and payment adjustments. CMS has now finalized a list of seven Advanced APMs for the 2017 FY, but the agency is also planning to add at least four new models to the list by the year 2018. ECs will be able to qualify as Advanced APM participants depending on the percentage of patients that they treat via Advanced APMs or the percentage of revenue they get from the system.
It is reported that ECs that qualify as Advanced APM participants in the year 2017 will be eligible for a lump sum bonus in 2019, which will be equal to five percent of the 2018 Medicare Part B revenue of the participating unit. ECs can also qualify as partial Advanced APM participants by meeting lower patient thresholds or revenue to be exempt from MIPS, yet again, these ECs will not be eligible for the five percent incentive payment.
Even though many of the stakeholders supported the addition of partial MIPS reporting, as it will save many ECs from negative payment adjustments for 2017, the new options introduced by CMS will have much impact on the positive payment adjustments. However, as per MACRA, the MIPS payment adjustment were to be budget neutral, which means that the positive payment adjustment should be equal to negative payment adjustments.
As per the new options in reporting, only those ECs that do not report any data will have a negative payment adjustment and the new partial reporting options make it really easy to avoid negative payment adjustment. It is expected that this will help to reduce the amount of negative payment reduction, which in turn would lower the capital for positive payment adjustments.