CMS Quality Payment Program: What Does the Low-Volume Threshold Mean to Your Practice? 


January 11, 2018

The Centers for Medicare and Medicaid Services (CMS) expanded its low-volume threshold for the 2018 reporting year under MIPS (Merit-based Incentive Payment System). Several specialty societies asked for the change because of the unique challenges faced particularly by small and rural practices.
 
Previously, providers who treated 100 or fewer Medicare Part B beneficiaries or billed Medicare Part B for $30,000 or less were not required to report under MIPS.
 
For the 2018 reporting year, the low-volume threshold has expanded to 200 or fewer Medicare Part B beneficiaries or $90,000 or less in charges. This change will provide more flexibility for clinicians who may not have enough data to participate in MIPS.
 
There will be no change for those providers who are non-patient facing. Those providers must continue to report unless they have 100 or fewer patient-facing encounters.

Those individuals who do not meet the low-volume thresholds, and do not report under MIPS, will be subject to a negative payment adjustment (+/- 4 in 2017 and +/-5% in 2018).

Reputation

Under the Physician Compare website, CMS will be publishing data for patients, employers and private insurance carriers to search your MIPS scores. With the complexity of the scoring system, patients will not understand why a provider did not submit data or if data was submitted, what is entailed with a "quality" score. They may assume that a MIPS score is an indication of the quality of care given by a provider.
 
Practices should keep track of their rating on the Physician Compare site and other sites like Health Grades, ZocDoc, Yelp, etc. Where rankings are low or reviews are negative, practices are at risk for fewer patient referrals, especially when a patient goes to the Internet to search.