Physicians and other health care providers concerned about whether they are required to report under the Merit-based Incentive Payment System in 2018 can now check their status at qpp.cms.gov/participation-lookup.
Don’t assume you’re required to report for 2018 just because you were included last year. CMS has raised the low-volume participation threshold to only include providers who receive at least $90,000 in Part B payments AND provide services to at least 200 Medicare patients (up from $30,000 and 100 in 2017). Falling below either one of those thresholds as an individual will exempt you from 2018 reporting and will ensure you receive no payment adjustment in the corresponding 2020 payment year.
Additionally, keep in mind that CMS is currently basing this determination on payment data from the fall of 2016 to the fall of 2017. Another status check will be performed later this year to determine whether an individual’s Medicare volumes changed significantly from fall 2017 to fall 2018. Providers who were initially tagged to participate during the first determination period may be removed from participation at that time. However, no previously exempt providers can be added to the participation list during the second status check.
Finally, don’t forget that these thresholds are applied at the group level for providers who elect to report through a registry or other group reporting methods. That means that even if you’re exempt as an individual, you will likely be required to report if your TIN elects to report as a group.
If you have any questions about your participation, or are trying to decide whether group or individual reporting would be most beneficial, don’t hesitate to contact us by calling 517-486-4262, or by emailing firstname.lastname@example.org.