Information on Your MIPS Participation Status Is Coming Soon; Here’s Help

The more than 33,0000 psychiatrists who see Medicare Part B patients will soon learn if they are subject to (or exempt from) Medicare’s new Merit-Based Incentive Payment System (MIPS). The MIPS program, along with incentives for “Advanced” Alternative Payment Models (APMs), together make up the new Medicare Quality Payment Program (QPP). The QPP replaces the Physician Quality Reporting System (PQRS), Meaningful Use (MU) for EHRs, and the Value-Based Payment Modifier (VM).

The Centers for Medicare and Medicaid Services (CMS) is now reviewing past Part B claims to see which practices and which physicians fall within the MIPS “low-volume threshold.” Practices billing no more than $30,000 in Medicare Part B allowed charges per year—or providing care for no more than 100 Part B enrolled beneficiaries—will be exempt from MIPS reporting for 2017. They will also be exempt from MIPS payment adjustments in 2019.  

Beginning later this month through May, each practice will receive a letter from the Medicare Administrative Contractor that processes Medicare Part B claims in its area. This letter will clarify the MIPS participation (or exemption) status for each MIPS “eligible clinician” (physician, physician assistant, or advanced practice nurse) associated with the Taxpayer Identification Number (TIN) for that practice.  

• CMS has estimated that 49% (16,521) of the 33,632 psychiatrists whose services are paid under Part B will qualify for the low-volume exemption.  
• Another 3,000 psychiatrists may be exempt because they just enrolled in Medicare this year (that is, for the first time) or they participate in an “Advanced” APM.

Psychiatrists subject to MIPS reporting requirements can still avoid a penalty with very little time and effort. Under this year’s “Pick Your Pace” transitional approach, all that is required to avoid MIPS penalties in 2019 is simply doing one of the following:  

• Report one MIPS quality measure for one patient.
• Report one MIPS Improvement Activity.

Reporting more complete MIPS data may lead to a MIPS bonus of up to 4%. Also, “exceptional performers” may earn an extra bonus of up to 10%. Future MIPS payment adjustments can be up to 5% in 2020; 7% in 2021; and 9% in 2021 and beyond. In contrast, in 2017, psychiatrists can be subject to penalties totaling 11% under PQRS, MU, and the VM; and up to 12% in 2018.

More Information and Assistance

APA is ready to provide you with the help you need to succeed in the new Quality Payment Program.

• The APA Payment Reform Toolkit has detailed fact sheets and links to recorded webinars about the MIPS program and incentives for “Advanced” APMs.  
• APA members can consult with APA staff experts by sending questions to qualityandpayment@psych.org or calling (800) 343-4671.
• Additional help is available from CMS on the Quality Payment Program website, by email at QPP@cms.hhs.gov, or by phone at (866) 288-8292. 
• To learn about participating in the Quality Payment Program through the APA mental health registry, PsychPRO, go to www.psychiatry.org/registry.