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There are a number of considerations you should take into account when determining how the Quality Payment Program (QPP) will impact your practice, and what options will be best for you and your patients.  

Are you exempt under the MIPS low-volume threshold?

Individuals and groups that submit $90,000 or less in Medicare Part B charges for covered professional services, see 200 or fewer Medicare patients, or provided fewer than 200 Medicare Part B covered professional services annually are exempt from MIPS in 2019.

Beginning in 2019, ob-gyns or practices that meet or exceed 1-2 of the above low volume threshold criteria can choose to opt in to MIPS participation. Those who choose to opt in will be treated as MIPS eligible clinicians, meaning their MIPS performance will be scored and they will receive a payment adjustment in 2021. Ob-gyns or practices that do not meet or exceed any of the above criteria are not eligible to opt in, and are automatically exempt.

You can also check your and your practice's eligibility on the QPP website.

Exempt physicians will receive a 0.5 percent payment adjustment to the Physician Fee Schedule in 2019 and no payment adjustment from 2020 to 2025 to the fee schedule.  In 2026 and beyond, exempt physicians will see fee increases of 0.25 percent to the Physician Fee Schedule.  MIPS reporting is voluntary for exempt physicians, but reporting won’t result in any additional payments.

Will the cost of reporting in MIPS exceed your negative payment adjustment?

If you are not exempt, or are considering opting in to MIPS participation, you should carefully examine how the infrastructure and staff costs required for MIPS reporting compare to your greatest potential payment cut in each payment year:

2021, 7 percent,

2022 and beyond, 9 percent. 

If you would report as an individual, check your previous year’s Medicare revenue to see how your practice would fare if you didn’t report and received the lowest possible score.  If reporting as a group, you’ll need to aggregate the revenue received from Medicare across all reporting providers in the group.    

 
 
 
 
 
 
 
  

Should you report as an individual or as a group?

Groups are identified by Tax Identification Number (TIN) and are defined as having two or more eligible clinicians who have reassigned their billing rights to the TIN. Consider whether reporting as a group may limit your ability to report on relevant quality measures if you’re in a multispecialty practice and whether multiple electronic health record (EHR) systems used by practices sharing the same TIN could complicate your reporting. 

If you are part of a group with many low-volume Medicare providers, you may want to consider advocating that everyone in your group report as individuals since the same low-volume threshold is applied to both individuals and groups.

You will have to un-assign your billing rights to the TIN if your group opts to report as individuals.  You cannot carve out low-volume providers from a group.

Cost-Conscious Cases:

Physicians have a responsibility to our patients and society to “do no harm” which includes providing cost-conscious medical care.

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