MIPS – Who Qualifies?  Who Cares?

The Merit-based Incentive Payment system (MIPS) is one component of the Medicare Access and CHIP Reauthorization Act of 2015.   If MIPS applies to your services action you take in 2017 will impact what you are paid in 2019.  A penalty for this year would result in a 4% reduction in Medicare payment in 2019 for the entire year or up to a 12% incentive payment.   This penalty can be easy to avoid and this article is a quick summary for providers that are impacted in 2017.

Who Qualifies?

The following Provider types qualify for Incentives or Penalties in 2019 based on services provided in 2017.

  • Physicians
  • Physician Assistants
  • Nurse Practitioners (Not for ACI in 2017)
  • Clinical Nurse Specialists
  • Certified Registered Nurse Anesthetists

The provider types above are eligible if they meet the following  items:

  • Have more than $30,000 a year in Medicare allowable charges. (Determination Period Applies)


  • Provide care for more than 100 Medicare Part B patients. (Determination Period Applies)


  • Are not new to Medicare Program in the calendar year 2017.
  • Are not participating sufficiently in an Advanced Payment Model and are not listed on the MIPS APM participant list in at least 1 of the following three snapshot dates. March 31, June 30, or August 31, 2017.

The low volume threshold will be calculated based on a “Determination Period”.   Initially, CMS will use data from services provided between September 1, 2015, and August 31, 2016, to identify and notify providers that qualify for the low-volume exclusion.    Then another measurement will be taken using data from September 1, 2016, through August 31, 2017, to identify excluded providers during 2017.

Who Cares?

If an eligible provider does not report performance data to CMS for 2017 they would receive a 4% reduction applied to all Medicare Part B services in 2019, (5% in 2020, 7% in 2021, and 9% in 2022 and beyond).   MIPS is very broad and there are so many options it can be daunting to create a strategy.   During 2017 it is our goal that none of our clients (or potential clients) should receive the penalty in 2019.   For many specialties, the 4% penalty can be avoided by simply by providing 1 reporting code during 1 visit.  Yes – it can be that simple to get started with MIPS in 2017.

At Medical Management Support Services we are always helping clients understand changes that will be impacting their practice and how to adapt to new regulations.   Contact us today to learn how we can help you navigate the Merit-based Incentive Payment Program (MIPS) and avoid a penalty or qualify for an incentive.