In early May, each practice enrolled in Medicare Part B (identified by its Taxpayer Identification Number, or TIN) will receive from its Medicare Administrative Contractor a letter regarding the Merit-Based Incentive Payment System (MIPS) participation status of the TIN and each physician and non-physician practitioner who bills under that TIN (identified by National Provider Identifier, or NPI). A recently released sample MIPS Participation Letter (including its two attachments) is available here.
The MIPS Participation Letters give each TIN a “heads up” regarding whether the TIN and/or each of the NPIs billing under the TIN qualify for the MIPS low-volume exception for performance year 2017 based on claims data from September 1, 2015, to August 31, 2016. Note that an individual physician will not receive a separate letter—only the TIN under which he or she bills for Medicare Part B services will.
Included with each letter is an attachment stating whether the TIN meets the low-volume threshold, i.e., $30,000 or less in Medicare Part B allowable charges, or claims billed under the TIN for 100 or fewer Medicare Part B beneficiaries. In this case, all NPIs billing under the TIN are excused from MIPS reporting requirements.
If the TIN exceeds the threshold, the attachment lists each NPI billing under the TIN that meets the threshold. If the NPIs billing under the TIN elect to report on MIPS measures individually, those NPIs that meet the low-volume threshold are excused from reporting.
If, however, the TIN elects to report as a group, the low-volume NPIs’ data will be included in that reporting, and those physicians and non-physician practitioners will receive an individual MIPS score (albeit the same score as other NPIs billing under that TIN). Keep in mind CMS will calculate a MIPS score for each NPI/TIN combination, and thus an NPI still may have to report under another TIN even if the NPI meets the low-volume threshold under one TIN.
The low-volume exception is not the only way in which a physician or non-physician practitioner may avoid MIPS reporting; the newly enrolled provider and Advanced APM exceptions also may apply. While the MIPS Participation Letter discusses these exceptions, it does not report whether an NPI qualifies for either exception.