MIPS eligibility snapshot updated, be sure to recheck 2019 status!

December 5, 2019

Are you participating in MIPS reporting for 2019? Now is a good time to recheck your 2019 eligibility, especially if you’re reporting as an individual and believe your Medicare volume is close to the low-volume thresholds that trigger reporting requirements.

CMS announced in a blog post Thursday that the MIPS eligibility snapshot has now been updated to focus on Medicare claims data from Oct. 1, 2018, to Sept. 30, 2019. All eligibility determinations from earlier in the year were based on data pulled between Oct. 1, 2017, to Sept. 30, 2018.

This means that even if you were informed you exceeded the volume thresholds to trigger reporting when you checked earlier this year, you may still be exempt from fulfilling your 2019 reporting requirements if this updated snapshot now lists you as exempt.

However, if you were listed as exempt earlier in the year, you are still exempt regardless of this updated window.

As a reminder, there are three volume thresholds that must be exceeded to trigger 2019 MIPS reporting requirements. Falling below any of these three as an individual provider or as a group will exempt you from reporting:

  1. Billed $90,000 or less in Medicare Part B allowed charges for covered professional services during either of the two determination periods (October 1, 2017 – September 30, 2018 or October 1, 2018 – September 30, 2019); OR
  2. Provided care to 200 or fewer Part B-enrolled patients during either of the two determination periods; OR
  3. New for 2019 – Provided 200 or fewer covered professional services under the Physician Fee Schedule during either of the two determination periods.

Keep in mind that if you are part of a group electing to report via registry, these volume thresholds will be applied to the group as a whole. That means even if you’re listed as individually exempt, you are still required to report alongside your group if the group elects to submit data collectively under your TIN. In this instance any bonus or penalty earned based on your reporting would be applied to all claims submitted through the TIN in 2021.

If you are reporting as an individual via the claims-based method, any bonus or penalty earned will be applied to your personal NPI. Bonuses and penalties for 2019 reporting are capped at +/-7% of your Medicare Part B claims in 2021, with additional bonus money available to exceptional performers.

Your MIPS reporting status can be checked here by entering your NPI. Feel free to reach out to us directly for assistance determining your 2019 requirements.

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