As the Centers for Medicare & Medicaid Services drags its feet on issuing final policy decisions, a major physician advocacy group points out that practices have been flying blind for nearly an entire quarter on the Merit-Based Incentive Payment System (MIPS).
In December, CMS promised a set of notifications to clinicians regarding the 2017 MIPS, but as of March those notifications have not come.
In a letter to Seema Verma, the current administrator of CMS, Anders M. Gilberg, senior vice president of Government Affairs for the Medical Group Management Association (MGMA), cites “considerable frustration and confusion” among providers seeking information vital to their MIPS transition plans.
MGMA’s letter specifies three crucial areas:
- Notification of current status as “hospital-based” or “non-patient-facing” practices. Until providers know their status, they are “unable to comply with certain program requirements and are afforded necessary flexibilities,” per MGMA.
- Notification regarding low-volume threshold exemptions. According to CMS estimates, 32.5% of Medicare providers will be exempt from MIPS reporting in 2017. Without details about the threshold, however, providers have no idea whether they are a part of that cohort.
- Lists of approved qualified registries for group practices deciding on a reporting solution. Group practices need to delay implementation on new reporting mechanisms or sign on with vendors without knowing they will meet the qualifications the CMS eventually announces.
The rollout of MIPS marks the first step in the implementation of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) and has caused providers a good deal of concern as they scrambled to understand the goals and requirements of the system designed to shift incentives away from volume of care and toward value.
Practices have faced a tight timeline and an array of necessary preparations ahead of the MIPS implementation, including technology upgrades and changes to processes to meet reporting requirements.