While most clinicians should have received their Merit-based Incentive Payment System (MIPS) eligibility letters by now, CMS has also recently provided groups a way to check online whether or not they are required to participate in the new quality reporting program. Individuals can check whether they fall below the Medicare volume threshold ($30,000 or less in Medicare payments or seeing 100 or fewer Medicare patients) or qualify for another exemption by entering their NPI here: https://qpp.cms.gov/learn/eligibility.
It’s important to note that if an individual doctor is told they don’t meet the thresholds to be forced to participate as an individual, they don’t have to report with clinicians in their group who do have to participate unless they elect to report as a group. In that case, even doctors who don’t meet the volume thresholds would be required to participate with their group. With that in mind, some of groups may decide it’s best to report as individuals instead of as a group if they have multiple members who don’t have to participate and would prefer to avoid being affected by bonuses or penalties.
CMS is basing its participation determinations on 12 months of data ranging from Sept. 1, 2015 to Aug. 31, 2016. Later this year, another assessment will be run based on data between Sept. 1, 2016 and Aug. 31, 2017. That means that even if someone is told right now that they have to participate, that may change later this year when later data is reassessed if their Medicare volumes went down between the two periods. Just as a reminder, clinicians enrolled in Medicare for the first time in 2017 are also exempt for this year.