2018 MIPS Information


2018 MIPS Step-by-Step Guides

The 2018 MIPS step-by-step guides provide information on calculating, collecting and reporting each MIPS performance category.

Please visit the MIPS web page for preliminary information on how to begin your participation in the MIPS program.  

 

Group Level 2018 MIPS Eligibility & Threshold Data

Physicians can now log in to the CMS QPP website to check their group’s 2018 MIPS eligibility. After logging into the feature using your EIDM credentials, browse to the Taxpayer Identification Number (TIN) affiliated with your group, and you will be able to click into a details screen to see the eligibility status of every clinician based on their National Provider Identifier (NPI) and find out whether they need to participate during the 2018 performance year for MIPS. Previously, the only option physicians had to access MIPS eligibility information was on an NPI-by-NPI basis using the MIPS look-up tool.

The updated QPP website also displays data outlining how many allowed charges and Medicare patients are attributed to each clinician and group, which provides clearer insight into how close a clinician is to the low-volume threshold. Clinicians and groups are now excluded from MIPS if they:

  • Billed $90,000 or less in Medicare Part B allowed charges for covered professional services under the Physician Fee Schedule (PFS) 
OR
  • Furnished covered professional services under the PFS to 200 or fewer Medicare Part B -enrolled beneficiaries

This means that to be included in MIPS for the 2018 performance period you need to have billed more than $90,000 in Medicare Part B allowed charges for covered professional services under the PFS AND furnished covered professional services under the PFS to more than 200 Medicare Part B enrolled beneficiaries.

CMS will not be sending out letters to advise physicians of their eligibility status this year so checking the QPP group level eligibility on your profile or using the MIPS look-up tool is the only way to determine or verify eligibility status. Eligibility rules in 2018 are different than in 2017 so status this year may be different than last.

 

2018 low-volume threshold eligibility is determined during two review periods:
First review - September 1, 2016 through August 31, 2017
Second review - September 1, 2017 through August 31, 2018
Note: The 2018 Participation Lookup Tool Update for Alternative Payment Model (APM) participants will be updated at a later time.
 

2018 MIPS - Limiting Traditional Medicare Patients to Avoid MIPS Participation 

Harris County 2016 Medicare Market Share Overview:

  • Total population (census report estimate) = 4,434,257
  • 65 and over (census report estimate) = 408,818
  • Medicare Advantage Plan enrollees = 204,506
  • Traditional Medicare beneficiaries = 204,312
 
Option 1: Medicare Opt-out
  • According to the Balanced Budget Act of 1997, a physician has the right to opt out of Medicare and still care for Medicare patients. 
  • Must complete an affidavit to opt out for a minimum of two years and send to Novitas, Texas Medicare Administrative Contractor. The affidavit information is put into the PECOS system (Medicare enrollment system) thereby allowing services ordered by an opt out physician to be covered by Medicare.
  • Must have a signed private contract with Medicare patients. The private contract informs patients that Medicare will not pay for the services physicians are providing and that there is no limit to what physicians may charge. 
  • Opt out is automatically renewed ever two years. A physician that does not want their opt out to automatically renew at the end of a two-year period may cancel the renewal by notifying Novitas in writing at least 30 days prior to the start of the next opt-out period.
  • To become a Medicare participating provider again, physicians must completely re-enroll in the 30-day period just prior to their opt-out renewal date. The enrollment forms must be completed again, either in PECOS or on paper, and a letter sent to Novitas stating you are cancelling your opted-out status. 
 
Option 2: Avoiding MIPS Requirements
  • MIPS Low-volume Threshold Exemption
    • Exemptions may change every MIPS performance year. 
    • 2018 - Individual physicians and group practices have the same low-volume threshold. This threshold is set at $90,000 or less in Medicare Part B allowed charges OR 200 or fewer Medicare Part B beneficiaries. You are exempt from MIPS if you are at or below these thresholds as identified by CMS (using the NPI lookup tool mentioned above). Note: It is possible to be exempt at the individual level but not at the group level. 
    • These thresholds are determined during CMS's predetermined review periods as mentioned above.
     
  • Hardship Exemptions
    • Exemptions may change every MIPS performance year. 
    • 2018 hardship exemption applications have not been published yet. 
     
 
Option 3: Strategies for Remaining Under MIPS Low-volume Threshold
  • Medicare Advantage Plans only or primarily
    • Medicare Advantage Plans are not subject to MIPS and their beneficiaries are not counted towards the low-volume threshold calculations. 
     
  • Accept only key referrals up to 200 Medicare patients during the review period - possibility of not exceeding the low-volume threshold
    • Physicians who accept traditional Medicare patients by referral only. 
     
  • Accept only on call up to 200 patients during the review period - possibility of not exceeding the low-volume threshold
    • Physicians who accept traditional Medicare patients by on-call only.
     
  • New Medicare FFS Patients
    • Accept only current patients aging into traditional Medicare - possibility of not exceeding the low-volume threshold.
     
  • Some combination of the above. 

 


 










 
Created by HCMS | Updated April 2018