Here we are half way through the first month of 2017. It is the perfect time to really dive into this MACRA/MIPS program and get a good understanding of how it will impact your practice. In previous blogs, I have discussed some of the financial impact along with details of the MIPS focus areas. Today, I thought it would be a good idea to take a step back and look at who is an Eligible Clinician for MIPS.
Let’s start with a few basics about the program for 2017. In 2017, CMS has established that the MACRA program will be in a transition year. There is a great deal of flexibility in how we approach the program.
You get to pick your pace for this year!
- Option 1 – Test the Quality Payment Program
- Option 2 – Participate for Part of the Calendar Year
- Option 3 – Participate for the Full Calendar Year
- Option 4 – Participate in an Advanced Alternative Payment Model
One of the first steps is determining who is eligible so that you can determine at which pace you want to participate. This is a large program that combines PQRS, Meaningful Use and adds a new area of focus for Clinical Improvement Activities. Knowing who is eligible will help you to make the right decisions for your practice.
The Eligible Clinicians are a combination of some of those that participated in PQRS and Meaningful use with a few exceptions for the 2017 transition year.
Who is An Eligible Clinician?
- Physician Assistant
- Nurse Practitioner
- Clinical Nurse Specialist
- Certified Registered Nurse Anesthetist
You will notice that some of these clinicians have not participated in Meaningful Use in the past. This may present an area that you will need to focus on if you are planning full or partial participation in the MIPS program for 2017.
There are Exclusions!
Low Volume Threshold
This is determined based on the Eligible Clinician’s billable charges during the performance period (CY 2017). If the Medicare Part B Fee for Service billed allowable charges are less than $30,000, the Eligible Clinician is excluded from participated in the MACRA program.
Medicare Beneficiary Totals
This is also determined based on the Eligible Clinician’s billable charges during the performance period (CY 2017). If the total number of beneficiaries with billed charges are less than 100, the Eligible Clinician is excluded from participated in the MACRA program. The total billed allowable amount does not impact this exclusion. This exclusion is specifically for those providers that may have only a few patient with high billable services.
Newly Enrolled Medicare Eligible Clinicians
This is defined as an Eligible Clinician who has not previously submitted claims under Medicare Part B as an individual, an entity or part of a physician group under a different billing number or tax identifier
There are Also Exceptions!
There are also several Exceptions within the MACRA ruling for certain types of providers. These providers are not “Excluded” from the program but will have specific exceptions within the measures selection process. CMS has recognized that these types of Eligible Clinicians may face difficulty in meeting the components of MIPS
- Non-Patient Facing Eligible Clinicians
- Pathologist working in laboratory
- Radiologist interpreting results
- Nuclear Medicine who consult dosing administration
- Anesthesiologist who primarily provide supervision to CRNA
- Small Practices with less than 15 Eligible Clinicians
- MIPS Eligible Clinicians located in rural areas
Having a full list of each Eligible Clinician in your practice will assist you in determining how many measures you have to select, the financial impact on your organization and your decision to report as individual clinicians or as a group.