Low-volume threshold expanded in 2018 Quality Payment Program rule

More psychologists will likely be exempt from reporting new Medicare quality measures.

The Centers for Medicare and Medicaid Services (CMS) announced Nov. 2, 2017, that it will expand the low-volume threshold (LVT) that exempts some Medicare providers from having to report under the Merit-based Incentive Payment System (MIPS).

For 2018, providers who treat 200 or fewer Medicare Part B beneficiaries or bill Medicare Part B for $90,000 or less in allowed charges will not be required to report under MIPS. In its comments on the proposed rule on the 2018 Quality Payment Program the Practice Organization endorsed increasing the LVT from its 2017 threshold of 100 or fewer Medicare Part B beneficiaries and $30,000 or less in allowed charges.

Psychologists are not yet required to report MIPS quality measures, but you may practice reporting now to prepare. CMS may add psychologists to the program in 2019, but many will likely be exempt from MIPS reporting under the expanded LVT.

MIPS was created under the Medicare Access and CHIP Reauthorization Act. This new payment system emphasizes value rather than volume.

Important changes for those reporting under MIPS

CMS is working to reduce the burden of reporting so that more clinicians can successfully participate.

In 2018, CMS will award five bonus points to a provider’s or group practice’s MIPS performance scores for the treatment of complex patients with multiple chronic mental and physical illnesses and conditions. CMS will also award five bonus points to the final scores of small practices with fewer than 15 clinicians next year.

Virtual Groups will be another option that CMS adds to MIPS for 2018. Solo practitioners and groups of 10 or fewer clinicians who exceed the LVT will be able to form or join a Virtual Group to report collectively on MIPS measures. Virtual Groups must have a written agreement signed by all clinicians that complies with Medicare’s requirements.

CMS is considering expanding Virtual Groups in 2019 to include solo practitioners and groups of fewer than 10 clinicians who exceed one but not both thresholds for the LVT.

New 2018 option for MIPS reporting

The Practice Organization offers a registry for psychologists and others interested in MIPS reporting. Developed by IT vendor Healthmonix, MIPSPRO is designed to facilitate reporting for clinicians who provide mental and behavioral health services.

For 2018 the Practice Organization is taking a leadership role in helping to define and measure quality mental and behavioral healthcare. Through our partnership with Healthmonix, the Practice Organization is developing a Qualified Clinical Data Registry (QCDR). A QCDR is a CMS-approved outcome dataset that will allow practitioners to track quality outcomes on their clients and patients using measures identified by experts in psychology as being the most meaningful to both practitioners and those we serve. In addition to enabling psychologists and other providers to continue reporting outcome measures to CMS, the QCDR will also help with benchmarking, negotiating with third-party payers, continuing education, credentialing or board certification requirements and clinical research.

For more information on Medicare, check out our Complete Guide to Medicare for Psychologists on APA Practice Central.