MGMA to CMS: Where are the MIPS eligibility notifications?

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The Medical Group Management Association (MGMA) has asked newly confirmed CMS Administrator Seema Verma to quickly release overdue eligibility information for the Merit-based Incentive Payment System (MIPS), one of two new payment tracks implemented as part of the Medicare Access and CHIP Reauthorization Act (MACRA).

This year is the first performance year for the MIPS, though qualified providers are being allowed to “pick their pace.” MGMA’s issue, however, is providers don’t know if they’re qualified.

“Contrary to the Agency’s own regulatory provisions and commitment to providing notifications last December, it is now three months into the 2017 performance period and CMS has failed to notify clinicians and group practices regarding low volume threshold exemptions, status as hospital-based or non-patient-facing, as well as approved lists of registry vendors,” wrote Anders Gilberg, MGMA’s senior vice president for government affairs. “This is generating considerable frustration and confusion.”

This would affect a significant number of clinicians. According to the final MACRA rule released by CMS, “almost half" Medicare clinicians wouldn’t qualify for MIPS in 2017, with the most common reason being they fall below the low-volume threshold: receiving at least $30,000 in Medicare Part B charges or treating at least 100 Medicare patients.

But without the full eligibility information they were expecting, providers aren’t being set up for success under MIPS, MGMA argued, considering the challenges the MACRA transition presents in regards 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.”

The letter went on to say group practices are also being left in the dark on MIPS. Gilberg wrote practices haven’t been given a final list of approved 2017 qualified registries and qualified clinical data registries or notification on whether CMS considers hospital-based or non-patient facing.

“To succeed in MIPS, clinicians and group practices require certainty as to their eligibility, as well as the eligibility of their vendor partners,” he wrote. “We urge CMS to expeditiously release these long overdue MIPS eligibility notices and approved vendor lists.”