MIPS applies to all physicians who treat Medicare Part B beneficiaries, except (i) physicians who have opted out of Medicare; (ii) physicians who are newly enrolled in Medicare; (iii) physicians who successfully participate in an Advanced APM and (iv) physicians who fall within the low volume threshold. 

For 2017, the low volume threshold will automatically exclude from MIPS participation any physician that (a) had Part B allowed charges of no more than $30,000 over a 12-month period or (b) provided care for no more than 100 Part B Medicare beneficiaries over a 12-month period.  Psychiatrists may verify whether they qualify for the 2017 low volume exclusion by entering their NPI in the CMS Lookup Tool at https://qpp.cms.gov/participation-lookup.  In addition, psychiatrists may have received a letter from National Government Services confirming their MIPS participation status. 

Avoiding a Penalty in 2019

Physicians who do not qualify for a MIPS exclusion in 2017 may avoid the 4% penalty slated for 2019 by successfully participating in one of the following MIPS categories:

1.  Quality:  perform and report on one quality measure for one patient.  CMS has now clarified that physicians may avoid a penalty under "pick your pace" reporting by performing and reporting one quality measure for one patient during the 2017 reporting period.  Quality measures reported via Medicare claims must be submitted no later than December 31, 2017. 


2.  Improvement Activity:  perform and report on one improvement activity by submitting an attestation to CMS.    


3.  Advancing Care Information:  perform and report on all five base score measures in connection with use of certified EHR technology. 

The APA recently released PsychPRO (Psychiatric Patient Registry Online), its new mental health registry.  Psychiatrists will be able to use the registry portal to submit MIPS quality reporting data and MIPS improvement activity reporting data to CMS.  Psychiatrists can sign up for PsychPRO at https://www.psychiatry.org/psychiatrists/registry.   In order to use PsychPro to meet MIPS reporting requirements for 2017, psychiatrists must register with PsychPRO no later than December 15, 2017. 

For additional information on how to participate in MIPS in 2017, click here to download the APA Fact Sheet entitled "Take Action Now to Avoid Medicare Penalties" which provides step-by-step instructions on how to successfully participate in MIPS in order to avoid a penalty in 2019. 

Updates for Calendar Year 2018

On November 2, 2017, CMS issued a final rule regarding Year 2 of the Medicare Quality Payment Program (calendar year 2018).  The final rule expands the MIPS low volume exclusion to apply to all physicians who (a) have Part B allowed charges of no more than $90,000 over a 12-month period or (b) provide care for no more than 200 Part B Medicare beneficiaries over a 12-month period.  Therefore, the 2018 low volume exclusion will apply to all psychiatrists who have $90,000 or lower in Part B allowed charges or who treat 200 or fewer Part B beneficiaries.  This change may significantly increase the number of clinicians automatically excluded from participation in MIPS in 2018. 

For additional information and resources, please see the APA Payment Reform Toolkit, a comprehensive guide to the Medicare quality payment program located at https://www.psychiatry.org/psychiatrists/practice/practice-management/coding-reimbursement-medicare-and-medicaid/payment-reform.