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MIPS

Eligibility & Exemptions
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Are you a MIPS Eligible Clinician?

Compared to the current CMS quality initiatives, the pool of eligible clinicians (formerly called eligible providers) will be shrinking significantly for the 2017 performance year. However, any clinician that bills Medicare Part B can practice reporting for MIPS in 2017. Considering that by 2019, when the pool of eligible clinicians will expand, the MIPS payment adjustment will be up to 9%, it is likely wise to report even if you are not an eligible clinician in 2017.

Performance Year
Adjustment Year
MIPS Eligible Clinicians
2017+
2019+
Physicians, Physician Assistants, Nurse Practitioners, Clinical Nurse Specialists, Certified Registered Nurse Anesthetists
2019+
2021+
Physical / Occupational Therapists, speech-language pathologists, audiologists, nurse midwives, clinical social workers, clinical psychologists, dietitians/nutritional professionals

Please note that CMS defines a physician as "a doctor of medicine, doctor of osteopathy (including osteopathic practitioner), doctor of dental surgery, doctor of dental medicine, doctor of pediatric medicine, or doctor of optometry, and, with respect to certain specified treatment, a doctor of chiropractic legally authorized to practice by a state in which he/she performs this function."

Possible Exemptions for MIPS Eligible Clinicians
1. Participation in an Advanced Alternative Payment Model (APM)

If an eligible clinician is a part of an Advanced APM, they are exempt from MIPS reporting. Current examples of APMs are Accountable Care Organizations (ACO), Patient Centered Medical Homes, and bundled payment models.

2. MACRA Quality Payment Program Low-Volume Threshold

Otherwise eligible clinicians or groups will be exempt from MIPS reporting if they bill ≤ $30,000 or provide care for ≤ 100 Medicare Part B patients.

3. Newly Enrolled in Medicare

If a clinician enrolls in Medicare in the middle of a performance year, they do not have to participate in MIPS reporting that year. For example, if a clinician was to enroll in Medicare on February 6, 2017, they will be exempt for the 2017 performance year (January 1, 2017- December 31, 2017).

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