According to CMS officials, what should a MIPS-eligible clinician do if she has not received a MIPS clinician participation letter?
A. Celebrate! It means the clinician does not have to participate in MIPS.
B. Check the address for her billing tax identification number (TIN). It may have gone to another location.
D. A and C.
E. B or C.
F. None of the above.
The correct answer is E. Remember that a number of clinicians are defined as eligible to report MIPS:
- Physicians.
- Physician's assistants.
- Nurse practitioners.
- Clinical nurse specialists.
- Certified registered nurse anesthetists and anesthesia assistants.
However, some eligible clinicians may be exempt from reporting this year.
During the May 22 QPP participation criteria webinar, CMS officials explained that to help eligible providers avoid the 4% pay cut that will be triggered by non-participation, the agency sent out letters that tell clinicians whether they should participate in MIPS this year. But remember, not all of those letters will go directly to a provider's practice.
CMS Senior Technical Advisor Kelly DiNicolo gave the example of a neighbor who works at a small practice. He and his fellow providers had not receive their letters because the practice bills under a local hospital's TIN and the letters went to the hospital.
In addition, a provider who reports under multiple TINs should have received a letter for each TIN. His eligibility requirements may be different depending on the work he does at each practice, so he should review each letter.
CMS officials also urged webinar attendees to
use the MIPS confirmation tool -- for which you'll need each clinician's NPI number -- if they haven't received the letter. In addition, it wants to hear from providers and practices who have questions about the letter or disagree with CMS' determination. Drop them a line at
qpp@cms.hhs.gov.