Three months into the 2017 performance period, the Centers for Medicare and Medicaid Services has left providers in the dark about whether they must comply with program criteria, according to the Medical Group Management Association.
In a letter to new CMS Administrator Seema Verma, in fact, the MGMA urged immediate release of 2017 merit-based incentive payment system eligibility information to determine which practices are exempt.
Clinicians and group practices that bill $30,000 or less in Medicare charges or give care to 100 or fewer beneficiaries fall under the low-volume threshold and are exempt from MIPS. CMS has estimated that nearly one-third of clinicians would be eligible for an exemption.
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"By CMS' own estimate, 32.5 percent of Medicare providers are exempt from MIPS in 2017 under the low volume threshold and, as such, at least 32.5 percent of Medicare providers are currently unsure whether they qualify for participation in MIPS," MGMA senior vice president Anders Gilberg noted.
In addition, CMS has failed to notify clinicians and group practices about hospital-based or non-patient facing status, which carry modified reporting requirements.
"Transitioning to MIPS is a challenge involving upgrades to electronic health record software, reengineering clinical workflows to meet data capture and reporting requirements, contracting with data registries, and training clinical and administrative staff," Gilberg said. "Without basic information about eligibility, physicians and medical groups are significantly disadvantaged from positioning themselves for success in the program."
Further hindering group practices' success in MIPS is the absence of a final list of approved 2017 qualified registries and qualified clinical data registries, he added. Group practices planning to use these reporting mechanisms must either delay engagement or partner with vendors without a guarantee they meet CMS' qualifications.
"We urge CMS to expeditiously release these long overdue MIPS eligibility notices and approved vendor lists," Gilberg said.