Am I required to participate in MIPS? A new primer for radiologists

The Merit-Based Incentive Payment System (MIPS), developed by CMS to pay physicians under the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015, is one of many things today’s imaging leaders must understand to help their groups stay ahead. According to a recent study in the Journal of the American College of Radiology, CMS exempts certain physicians from participating in MIPS, but many radiologists will find they must participate.

Using a sample of 1,000 Medicare-participating radiologists, the study’s authors searched the CMS MIPS Participating Lookup Tool to see who had to participate in the payment system and who was excluded altogether. Overall, 55 percent of radiologists were required to participate as individuals when considering a single associated taxpayer identification number (TIN). When considering all associated TINs, however, that number jumped to 83 percent.

“Most radiologists participate in Medicare across multiple TINs,” wrote lead author Andrew B. Rosenkrantz, MD, MPA, of the department of radiology at NYU Langone Medical Center in New York City, and colleagues.

At the group level, 97 percent of radiology groups were required to participate in MIPS, a statistic that specialists hoping to avoid the payment system altogether won’t be happy to learn.

“The high likelihood of needing to participate in MIPS held true regardless of generalist versus subspecialist and academic versus nonacademic practice patterns, as well as for small and rural practices alike,” the authors wrote. “Therefore, although certain groups may anticipate being eligible for relaxed reporting requirements, MIPS participation will remain the reality for the bulk of Medicare-participating radiologists and groups.”

Rosenkrantz et al. also explored the various special statuses that exist for radiologists. For instance, if an individual has “infrequent face-to-face patient interactions” they can receive non-patient-facing status. Or if “a large majority of one’s services are furnished in the hospital setting,” they can receive hospital-based status.

“Physicians receiving either special status are exempt from MIPS requirements measuring performance on utilization of certified electronic health records technology in the advancing care information performance category; those receiving the non-patient-facing status additionally may report a fewer number of improvement activities,” the authors wrote.

While 91 percent of individual radiologists and 72 percent of group practices were assigned non-patient-facing status by CMS, 71 percent of individuals and 25 percent of groups were assigned hospital-based status.

In addition, 23 percent of individual radiologists and 39 percent of groups were assigned health professional shortage status by CMS. Thirteen percent of individuals and 27 percent of groups were assigned the rural status.

“Because the large bulk of radiologists will be required to participate in MIPS, whether at the individual or group level, radiologists are strongly encouraged to carefully review their own MIPS participation and special statuses using the publicly available CMS resource to improve their ability to successfully navigate the program and thereby receiver higher performance scores and payment bonuses,” the authors concluded.

Additional coverage of MACRA and MIPS can be found here.