MACRA/MIPS and low-volume providers

Physicians and other Eligible Clinicians (ECs) classified as “low-volume” providers are exempt from the Medicare Quality Payment Program incentive payments or penalties. In order to be classified as a “low-volume” provider, the physician or other EC must have Medicare claims with an aggregate allowable cost volume of $30,000 or less during either of the two previous calendar years OR submitted Medicare claims for fewer than 100 Medicare patients during either of the two previous calendar years.

2017 is the first “reporting year” for the Quality Payment Program initiative. 2017 reporting will affect 2019 Medicare payments. Technically, the low-volume provider notification letters were to have gone out in December 2016. They have not yet been sent. In response to an inquiry from a representative of the College about the status of the notification letters, CMS sent the following statement:

CMS has committed to letting clinicians know whether or not they meet the volume thresholds for participation in the Merit-based Incentive Program (MIPs) this spring. Clinicians need this predictability so that they can plan for the first year of the program. As part of this commitment, CMS must ensure that what we send to clinicians is understandable so that clinicians and practices can rely on this information to make decisions. 

CMS is actively working with clinicians in the field to receive feedback on the information we plan to send out. We have received valuable input to ensure that we are sending out letters with easy-to-understand, actionable information.

The College has encouraged CMS to release the letter as quickly as possible so those physicians and other ECs who are exempt from 2017 Quality Payment Program reporting will know they do not have to submit data for 2017 or fear a negative payment adjustment in 2019.

We heard recently that CMS is hoping to have the letters sent by mid-April – we’ll keep you posted with any other developments.

Advocacy Issue: 
Billing, Coding & Payments