Making sense of the Medicare Access and CHIP Reauthorization Act: The low-volume threshold

This is the first in a new series of articles on how psychologists fit into Medicare’s new payment models.

The Medicare Access and CHIP Reauthorization Act (MACRA) went into effect in January, implementing new quality-based payment models for Medicare providers. This year physicians who see Medicare patients have to report quality measures to the Centers for Medicare and Medicaid Services under MACRA’s Merit-based incentive Payment System, referred to as MIPS, if they are not participants in an Advanced Alternative Payment Model (Advanced APM).

Decisions made by CMS often influence commercial insurers, so other health insurance companies could adopt similar quality-based payment models in the future.

Psychologists are not required to participate in MIPS until 2019, but you can practice reporting over the next two years using MIPSPRO, the APA Practice Organization’s online registry for reporting MACRA/MIPS. Using MIPSPRO now to report quality measures gives you time to observe how MACRA’s new payment models are implemented, and more time prepare before MACRA/MIPS reporting is required. Psychologists who take advantage of this option will not be subject to MIPS penalties, nor will they receive MIPS incentives in 2017.

In January, the Practice Organization hosted a webinar for psychologists that included information about MACRA and MIPS reporting. Diane Pedulla, JD, director of regulatory affairs at the Practice Organization, answered several questions about the law and how it will affect you and your practice. In this article and in the next several issues of PracticeUpdate, Pedulla will address more of your questions about MACRA, MIPS and Medicare.

What low volume threshold means for psychologists

What is MACRA’s low-volume threshold exemption?

The low-volume threshold exemption is a provision of MACRA that exempts certain health care providers from reporting under MIPS. If psychologists or other health care providers treat 100 or fewer Medicare beneficiaries or have $30,000 or less in Medicare charges, they are exempt from MIPS reporting and will have no MIPS adjustments to their payments. The Practice Organization sent a letter to CMS advocating for this exemption to reduce the burden of reporting on smaller psychology practices. This threshold could change by the time psychologists are included in MIPS in 2019.

What if I have fewer than 100 patients, but have more than $30,000 in Medicare allowed charges, am I exempt from MIPS?

Yes; for 2017, an eligible clinician — a physician, physician assistant or advanced-practice nurse — only needs to meet one of these two requirements to be exempt MIPS reporting.

Does 100 patients mean 100 individuals, or 100 patient visits within a year?

It means 100 unique patients, not patient visits.

If my group practice meets the low-volume threshold, can we participate in MIPS?

No; for 2017, an individual or group practice exempt from MIPS does not have the option of choosing to participate.

As a group practice, we see more than 100 Medicare individuals. Individually, we each see less than 100. How will CMS assess us regarding MIPS?

If you choose to participate as a group then the group will be required to report under MIPS. If you choose to participate in MIPS as individuals, then each individual provider would be exempt from MIPS reporting.

If you are exempt due to the low-volume threshold, do you still get a 4 percent reduction for not participating in MIPS?

No; if you are exempt from reporting then your Medicare payments are not impacted by MIPS.


Have a question about MACRA’s low-volume threshold or another aspect of the law?  Send an email. For more resources on Medicare enrollment and payment, visit the Complete Guide to Medicare for Psychologists.