This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.
In the MACRA final rule, the timeline for MIPS was largely the same. However, I think there was some confusion on the MIPS timeline. So, while this isn’t a change from the MACRA proposed rule, I thought it would be worth highlighting the MIPS timeline for those that will be participating in the MIPS part of MACRA.
This graphic is the most succinct illustration of the MIPS timeline I’ve seen:
As a summary, data for MIPS will be collected during 2017. How much data needs to be collected depends on which “Pick Your Pace” option you choose (more details on this in a future post). You must submit your MIPS data by March 31st following the performance year. Then, the positive or negative payment adjustment will happen the year after. For example, the 2017 MIPS performance year will determine your Medicare adjustment that goes into effect in 2019.
There was a slight change in who is eligible for MIPS in the MACRA final rule that is going to have a big impact. First, let’s take a look at who is eligible for the MIPS program:
As you’ll see, there isn’t really a change in which types of providers are eligible for MIPS. However, you do have to have $30,000 in Medicare Part B billing and 100 Medicare patients a year in order to be able to participate in MIPS. Currently this is done on a per provider basis. They’re still considering virtual groups in future years.
There are 3 exceptions for providers that aren’t eligible to participate in MIPS. The newly enrolled doctors and Advanced APMs participants is the same as it was in the final rule. However, the low-volume threshold exception now excludes you from participating in MIPS if you have less than $30,000 in Medicare Part B or see 100 or fewer Medicare Part B patients. That’s a change from the proposed rule.
Here’s the full outline of the 3 MIPS exemptions:
That’s a quick look at the MIPS Timeline and Eligibility from the MACRA final rule. Next week we’ll dive into the details for Pick Your Pace. That should help you make a determination for how your practice should approach MIPS in 2017.
Be sure to check out all of our MACRA Monday blog posts where we dive into the details of the MACRA Quality Payment Program.