In the 2018 Quality Payment Program (QPP) final regulation, the Centers for Medicare & Medicaid Services (CMS) outlined some provisions that accommodate small practices. These include the increased low-volume threshold, bonus points for small practices with 15 or fewer clinicians, and favorable scoring for small practices under the quality category of MIPS. Many current CAP members are in small practice settings and may be able to take advantage of these provisions for the 2018 reporting year.
The CMS expanded the low-volume threshold that exempts some Medicare providers from having to report under MIPS.
Under an Arizona law enacted in 2016, pathologists are prohibited from ordering genetic tests on a patient specimen “without the specific written consent of the subject.” As reported in the January 30 edition of STATLINE, the CAP and ASP have long argued that because the definition of genetic test in the law is overly broad, pathologists were legally hindered from ordering or requiring the performance of genetic testing to diagnose a patient for optimal patient care.
In 2017, the CAP advocated for relief for small pathology practices. Therefore, the CMS increased the low-volume threshold to less than or equal to $90,000 in Medicare Part B allowed charges, or less than or equal to 200 Medicare Part B patients for 2018. According to the CMS numbers, this excludes an estimated additional 2,000 pathologists from MIPS in 2018. Subsequently, if your practice meets these requirements, you do not need to report on MIPS for 2018.
Additional Provisions for Small Practices
If your practice is eligible to report on MIPS and has 15 or fewer clinicians, the CMS will award five bonus points to a provider’s or group practice’s MIPS final scores.
Moreover, the CMS will award small practices three points for reporting on measures in the quality performance category regardless if they meet data completeness requirements. One point will be awarded to those eligible clinicians that are not in small practices.
If you have questions, please review the MIPS FAQs under CAP Resources.
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