The Centers for Medicare and Medicaid Services (CMS) has released the Proposed Rule for the 2018 Performance Year under the Quality Payment Program (QPP). For those in the MIPS payment track, there are some surprising changes that could make you feel a little more jubilant about the upcoming 2018 Performance Year. More specifically, the change to the low-volume performance threshold is going to leave some clinicians feeling downright euphoric.
As you well know, during the 2017 Performance Year the low-volume performance threshold was set at equal to or less than $30,000 in Medicare Part B payments or equal to or less than 100 Medicare Beneficiaries. This meant that if during 2016, you received $30,000 or less in Medicare Part B payments, you were excluded from participating in MIPS. Because it is an either/or situation, you could have received more than $30,000 in Medicare Part B payments but if you treated 100 or less Medicare Beneficiaries, you were also exempt from participating in MIPS. This low-volume threshold meant that more than 30% of all eligible clinicians were exempt from MIPS and would not be obliged to participate in the heavying reporting requirements the program imposes on its participants.
The majority of solo and small practices, especially those located in rural areas, are going to be ecstatic at the new low-volume threshold CMS is proposing for the 2018 Performance Year. This is because they are tripling the amount of payments you can receive and doubling the number of patients you can see while still falling under the low-volume performance threshold that provides an exemption from MIPS participation!
For 2018, CMS proposes that clinicians who, during 2017, received equal to or less than $90,000 in Medicare Part B payments are exempt from participation in the MIPS payment track. Alternatively, clinicians who treated equal to or less than 200 Medicare Beneficiaries will likewise be exempt from the program. Once again, this is an either/or situation so by meeting either of these qualifications, you can be exempt from participating in MIPS altogether. CMS estimates that nearly 600,000 clinicians will fall under the increased low-volume threshold.
While at this time, the new low-volume threshold is only a “proposed” threshold, it is clear that CMS is doing its best to relieve some of the burdens that the QPP has brought to small and rural practices. Be on the lookout for the Final Rule to be released early this fall to confirm that the new low-volume threshold has, indeed, become finalized.