Time to check your 2019 MIPS eligibility status

It’s a new year, which means it’s a new performance period for Medicare’s Merit-based Incentive Payment System (MIPS). If you are unclear whether MIPS applies to you in 2019, you can check your eligibility with the Quality Payment Program (QPP) Participation Status Tool by entering your National Provider Identifier (NPI).

To determine your 2019 MIPS eligibility status, the Centers for Medicare & Medicaid Services (CMS) reviews both data from the Provider Enrollment and Chain/Ownership System (PECOS) and Medicare Part B claims for services provided between two 12-month segments called the MIPS determination period: between Oct. 1, 2017, and Sept. 30, 2018 (with a 30-day claims run out period), and between Oct. 1, 2018, and. Sept. 30 of this year.

The QPP Participation Status Tool currently shows your preliminary 2019 eligibility status based on the Oct. 1, 2017-Sept. 30, 2018, data. Later this year, CMS will use data from Oct. 1, 2018-Sept. 30, 2019 to update the tool with your final 2019 MIPS eligibility status. If you joined a new practice and started billing to a new or different tax identification number after Sept. 30, 2018, CMS will evaluate your eligibility under that practice during the second segment of the MIPS determination period.

CMS has updated the low-volume threshold criteria for the 2019 performance year. Physicians and groups are excluded from MIPS in 2019 if, during either segment of the MIPS determination period, they meet one of these criteria:

•    Bill $90,000 or less in Medicare Part B allowed charges for covered professional services payable under the Physician Fee Schedule.
•    Furnish covered professional services to 200 or fewer Medicare Part B-enrolled beneficiaries.
•    Provide 200 or fewer covered professional services to Medicare Part B-enrolled beneficiaries.

If you exceed all three elements of the low-volume threshold you are MIPS-eligible, although you must continue to exceed all three elements in the second segment to remain that way. If you exceed one or two of the criteria, you can elect to “opt-in” to MIPS, which means you will receive a MIPS payment adjustment in 2021. If you do not exceed any of the low-volume threshold criteria, you can still voluntarily report to MIPS and will receive a MIPS final score but no payment adjustment.

For more information, you can:

•    Visit the About MIPS Participation page on the Quality Payment Program website.
•    View the 2019 MIPS Quick Start Guide.
•    View the 2019 MIPS Eligibility and Participation Fact Sheet.
•    Contact the Quality Payment Program at QPP@cms.hhs.gov or 1-866-288-8292 (TTY: 1-877-715-6222).

– Kent Moore, Senior Strategist for Physician Payment at the American Academy of Family Physicians