Posted by Don M. Cross, DC, CPCO on February 01, 2017
Opting out of MIPS and MACRA: Are you an “AND” or an “OR”?
Confusing isn’t it! Most doctors are confused about MACRA and what it will mean to them and their practices over the next few years. During one of my recent webinars, a doctor asked me to clarify about whether he could opt out of the MIPS program (part of MACRA).
MIPS participation vs opting out of MIPS is a crucial decision for nearly all solo or small practices.
A recent CMS training presentation said clinicians below the low-volume threshold can be excluded from MIPS, and described two criteria to be eligible for exclusion. According to CMS, these criteria are “Medicare Part B allowed charges less than or equal to $30,000 OR 100 or fewer Medicare Part B patients”. Note: they emphasized the OR. In other words, if your practice meets either criterion, you can opt out of MIPS, and you are an “OR.”
The confusion comes in if you are an “And” provider? You are not able to opt out of MIPS if you fall into this category. Per CMS, “Medicare Part B clinicians billing more than $30,000 a year and providing care for more than 100 Medicare patients.” Again the bold in the quote was their emphasis.
CMS understands that this is a critical point for the solo practicing doctor and those in small practices. Now you must determine from your past billing patterns, do you meet either criteria? Next you will need to make an educated prediction of whether you will meet the criteria in 2017. THEN you can decide whether to opt out or not, unless you are an “AND”, then you’re stuck.
Bottom line: If you’re an “AND”, you must decide which of the four methods you will choose to begin your participation in MIPS.
Join me in future chiropractic compliance webinars, as I provide the basic information needed by solo practicing doctors or those who are in small practices to survive in this new “payment for quality” environment.