MIPS Eligibility & Exemptions in 2018



Who is considered a MIPS eligible clinician?

Compared to the current CMS quality initiatives, the pool of eligible clinicians will be shrinking significantly for the 2018 performance year. However, any clinician that bills Medicare Part B can report MIPS in 2018 and receive a feedback report. 

Performance Year

Adjustment Year

MIPS Eligible Clinicians

2017+

2019+

Physicians, Physician Assistants, Nurse Practitioners, Clinical Nurse Specialists, Certified Registered Nurse Anesthetists

2019+

2021+

Physical / Occupational Therapists, speech-language pathologists, audiologists, nurse midwives, clinical social workers, clinical psychologists, dietitians/nutritional professionals

Please note that CMS defines a physician as “a doctor of medicine, doctor of osteopathy (including osteopathic practitioner), doctor of dental surgery, doctor of dental medicine, doctor of podiatric medicine, or doctor of optometry, and, with respect to certain specified treatment, a doctor of chiropractic legally authorized to practice by a state in which he/she performs this function.”

Possible Exemptions for MIPS Eligible Clinicians

1

Participation in an Advanced Alternative Payment Model (APM)

If an eligible clinician is a part of an Advanced APM, then they are exempt from MIPS reporting. Current examples of APMs are Accountable Care Organizations (ACO), Patient Centered Medical Homes, and bundled payment models.

2

MACRA Quality Payment Program Low-Volume Threshold

Otherwise eligible clinicians or groups will be exempt from MIPS reporting if they bill ≤ $90,000 or provide care for ≤ 200 Medicare Part B patients.

3

Newly Enrolled in Medicare

If a clinician enrolls in Medicare in the middle of a performance year, they do not have to participate in MIPS reporting that year. For example, if a clinician was to enroll in Medicare on February 6, 2018, they would be exempt for the 2018 performance year (January 1, 2018- December 31, 2018).


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