Merit-based Incentive Payment System: What doctors should know

Excerpted from page 44 of the May/June 2022 edition of AOA Focus.

For 2022 and 2021, the Centers for Medicare & Medicaid Services (CMS) had broad exemptions available due to the COVID-19 pandemic. If conditions continue to improve, however, we may not see the same flexibilities available. Doctors of optometry should be aware of their Merit-based Incentive Payment System (MIPS) reporting requirements. To verify whether you will need to submit data for MIPS, use the CMS MIPS participation lookup tool.

Know the exclusions

Doctors who qualify for an exclusion from MIPS will not be required to meet program criteria if they meet any of the following Low Volume Threshold criteria:

Exclusion 1:

New Medicare-enrolled physicians
If 2021 is your first year submitting claims to Medicare.

Exclusion 2:

Low Volume Threshold
If you have Medicare allowable charges less than or equal to $90,000; or if you provide care for 200 or fewer Part B-enrolled Medicare beneficiaries; or provide less than or equal to 200 covered professional services.

Exclusion 3:

Qualifying APM Participants (QP) and Partial Qualifying APM Participants (Partial QP)
If you participate in a qualifying advanced alternative payment model (think accountable care organization).

Small-practice flexibilities

For the past several years, the AOA also has been advocating for additional MIPS flexibilities for small practices. Small practices are eligible for certain program flexibilities. You can qualify for these flexibilities if you are one of 15 or fewer clinicians billing under the practice’s tax identifier number (TIN) or if 15 or fewer clinicians bill under the practice’s TIN.

If you’re identified as a small practice, you’ll earn two times the points for each improvement activity you submit.

If you submit at least one quality measure, you also will receive six bonus points in the quality performance category.

Beginning with the 2022 performance year, you also qualify for automatic reweighting of the Promoting Interoperability performance category to 0%. The 25% category weight will be redistributed to other performance categories unless you choose to submit Promoting Interoperability data.

AOA MORE status

For 2022, the pause on AOA MORE will continue and AOA MORE will not be available for the quality reporting category under MIPS. The AOA is fully committed to assisting doctors in successfully participating in MIPS despite this ongoing pause in AOA MORE. Please contact AOA Chief Strategy Officer Kara Webb with any questions or concerns.

Coding questions? Submit them to AOA’s Coding Experts.