The Merit-based Incentive Payment System (MIPS) is one of the two tracks offered under the Quality Payment Program for Medicare that seeks to combine and streamline existing compliance programs with a goal of easing clinical burden while promoting quality care. However, not everyone is qualified to participate in this program. Answer the questions below for yourself to see if three key factors exempt you from participation.
1. Are you considered an Eligible Clinician? Only those who meet the definition of an Eligible Clinician (formerly known as Eligible Provider) are required to participate. According to CMS in 2018, Eligible Clinicians include the following:
- Physicians (including doctors of medicine, doctors of osteopathy, osteopathic practitioners, doctors of dental surgery, doctors of dental medicine, doctors of podiatric medicine, doctors of optometry, and chiropractors)
- Physician assistants
- Nurse practitioners
- Clinical nurse specialists
- Certified registered nurse anesthetists
- Groups or virtual groups that include one or more of the clinician types above
2. Do you bill to Medicare for the services you provide? If you’ve answered no, it makes thing simple—you are off the hook! If the answer is yes, keep reading to determine if you are exempt.
3. How much do you bill to Medicare and how many Medicare patients do you see? Not all providers billing to Medicare qualify to participate. In fact, if you meet any of the following conditions, you are exempt from participating:
- Clinicians or groups that have billed $90,000 or less in services furnished to Medicare Part B Fee-for-Service (FFS) beneficiaries (including Railroad Retirement Board and Medicare secondary Payer)
- Clinicians or groups with 200 or fewer Medicare Part B Beneficiaries
- Clinicians who enroll in Medicare for the first time in 2018
If you don’t qualify for MIPS, there are still many advantages that will benefit your practice and your patient’s care by using an EMR that monitors MIPS guidelines that are relevant to your specialty. For example, Health Information Exchange provides a defined, universal format that allows for patient information to be shared and ‘digested’ as discrete data between certified EMR providers. This facilitates strong communication between providers and patients, which will improve productivity and reduce healthcare costs while improving the quality of patient care.
The shift from a complete certification to modular certification, now more than ever, allows vendors to identify and support their customer needs based on the specialty care they are currently servicing rather than features that won’t be used by the providers with a complete certification. Stay tuned for a future post that breaks down some benefits of a modular certification.
Sheila Cougras is a Register Nurse with a background in disease management, leadership, and compliance and has been serving as the Director of Product Compliance at Net Health for over 10 years. She is an expert in monitoring and interpreting regulations that impact Employee Health, Occupational Medicine, and Urgent Care. Prior to working at Net Health, she was a Regional Director of Clinical Operations and Senior Director of Surgical and Perioperative Services. One of her latest focuses is keeping up with the changes within the Merit-based Incentive Payment System (MIPs).