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Pathologist group practices can now check their eligibility for the 2018 MIPS performance year by using the Centers for Medicare & Medicaid Services (CMS) Merit-based Incentive Payment System (MIPS) Participation Lookup Tool. This tool is available to check 2018 MIPS group reporting eligibility. Since the Participation Lookup Tool is now available, the CMS will no longer send out eligibility letters to physicians.

In the past, the eligibility look-up tool was only searchable by individual National Provider Identifier (NPI). After groups log into the updated website using Enterprise Identity Management (EIDM) credentials, they will be able to see the eligibility status for every clinician in the group and determine who needs to participate in MIPS in 2018.

The CAP recently learned that the CMS will not be sending out letters to physicians regarding their eligibility status this year. Therefore checking the QPP participation status look-up tool (or logging in using your EIDM for group practices) is the only way to confirm eligibility status. Please keep in mind that exempt individual clinicians still will need to report if their group is eligible and chooses to report as a group.

After logging into the feature using your EIDM credentials, browse to the Taxpayer Identification Number (TIN) affiliated with your group, and you will be able to access a details screen to see the eligibility status of every clinician based on their NPI and find out whether they need to participate during the 2018 performance year for MIPS.

Don’t have an EIDM account? Refer to the Enterprise Identity Management (EIDM) User Guide for instructions.

You can also use the MIPS Participation Lookup Tool to find out whether individual clinicians are eligible for the 2018 performance year without needing to login to the feature.

CMS Changes to Low-Volume Threshold

To reduce burdens on small practices, the CMS changed the eligibility threshold for 2018 to make more small practices and clinicians exempt from reporting. Therefore, if you were not exempt from MIPS in 2017, you may now be exempt from reporting this year. It is beneficial to check your eligibility again for 2018.

Based on the 2018 regulation, clinicians and groups are now excluded from MIPS reporting if they:

  • Billed $90,000 or less in Medicare Part B allowed charges for covered professional services under the Physician Fee Schedule (PFS), or
  • Furnished covered professional services under the PFS to 200 or fewer Medicare Part B-enrolled beneficiaries

To be included in MIPS for the 2018 performance period, you need to have billed more than $90,000 in Medicare Part B allowed charges for covered professional services AND furnished services to more than 200 Medicare Part B enrolled beneficiaries.

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In a big win for the CAP and the New Hampshire Society of Pathologists (NHSP), the New Hampshire Legislature on May 10 passed a bill prohibiting balance billing and requiring the Insurance Commissioner to address network adequacy for hospital-based physicians, including pathologists. The Governor of New Hampshire will likely sign this bill into law soon.

The CAP, along with NHSP and other physician and patient advocacy groups, has been advocating for networking adequacy in New Hampshire for more than four years. In June 2016, the NH Commissioner of Insurance Roger Sevigney declined a formal request from the CAP and the NHSP to include physician pathology services in the state’s proposed health plan network adequacy rules. At the time, the New Hampshire Breast Cancer Coalition and the New Hampshire Prostate Cancer Coalition sent letters strongly urging the Insurance Commissioner to reverse that decision and to expressly include physician pathology services in health plan network adequacy rules.

“We believe that the intentional omission of any physician pathology service, in a list of necessary medical services that is exhaustive and comprehensive for the effective evaluation of a health plan’s network adequacy, is detrimental to patients being screened, monitored or treated for cancer,” wrote Richard Hatin, president of the NH Prostate Cancer Coalition, in a letter sent Aug. 23, 2016.

HR 1809 does not define the “commercially reasonable” payment to be made by health plans to physicians for out-of-network (OON) services but instead confers authority on the Insurance Commissioner to determine such amounts. Under the amended bill, the Commissioner may require mediation between the health plan and the provider prior to making a decision. The CAP believes that the absence of any adverse payment formula makes this a favorable bill for physicians.

The CAP has long been a strong proponent of network adequacy. Specifically, the CAP advocates for state regulators to require health plans to ensure patients at in-network facilities have reasonable access to in-network providers. The CAP will continue to advocate for network adequacy in states that have not already passed such laws or rules.

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It’s the third week of the 2018 Practice Leader Survey and Maria Belinda M. Ramos, DO, FCAP, is this week’s winner of the $150 Amazon gift card. Dr. Ramos was randomly selected for completing the 2018 Practice Leader Survey.

It’s not too late to complete the 2018 Practice Leader Survey and win a $150 Amazon gift card. Help the CAP by providing your latest information about practice demographics, patient case mix, staffing trends, impacts of mergers and acquisitions, and the impact from regulatory issues and an evolving healthcare marketplace.

Data from these surveys are critical to helping the CAP understand the services pathologists are providing, where they are providing those services, how long they have been in practice, their income, and retirement plans. This information helps the CAP understand which advocacy issues are most important to our members and helps us provide data to support our positions with lawmakers and regulators.

The 2018 Practice Leader Survey is the second CAP Policy and Advocacy survey targeting pathology practice leaders. Practice leaders should have received an email with the survey link. The link will also be sent to many practice managers and administrators with a request that they bring the survey to the attention of their practice leader. CAP members should encourage their practice leader to take the survey, which only takes about 20 minutes to complete. There will be one survey per practice.

Those practices that complete the 2018 PLS will be eligible to win one of three $150 Amazon gift cards. The PLS is confidential. Anyone taking the survey will remain anonymous and results will only be shared in aggregate form.

All survey participants will be able to view an exclusive webinar that will review the findings later this year.

For questions about completing the survey, or if you want to make sure that your practice leader received the survey, please email

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