MIPS Tip Tuesday

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MIPS Tip Tuesday:

Did you know that certain mid-level providers will be subject to MIPS as well?mips-tips-2

Starting next year, nurse practitioners, physician assistants, clinical nurse specialists and certified registered nurse anesthetists will be subject to MIPS as well. The only time they will be excluded is if they are a newly enrolled Medicare provider or if they meet the low-volume thresholds (Medicare Part B allowed charges less than or equal to $30,000 a year OR sees 100 or fewer Medicare Part B patients a year).

This means that mid-levels will also need to participate in the Advancing Care Information (ACI) portion of MIPS (also known as the new MU). In today’s world, mid-levels are excluded from the current Meaningful Use program. Starting next year, if a mid-level provider doesn’t report on the ACI measures (in the event there are not sufficient measures applicable and available), CMS will assign a weight of zero to the Advancing Care Information performance category, and the Quality category will become over-weighted to 85 percent!

CMS encourages all NPs, PAs, CNSs and CRNAs to report on the ACI measures to the extent they are applicable and available; however, CMS states that it understands that some NPs, PAs, CNSs and CRNAs may choose to accept a weight of zero for this performance category if they are unable to fully report the ACI measures.

Was today’s tip helpful? Join the conversation.

Diana Strubler, Policy and Standards Senior Manager, joined AcumenDiana Strubler in 2010 as an EHR trainer then quickly moved into the role of certification and health IT standards subject matter expert. She has successfully led Acumen through three certifications while also guiding our company and customers through the world of Meaningful Use, ICD-10 and PQRS.


    • Diana Strubler says

      Hey Margaret!

      Happy holidays to you!

      If your NPs round in the dialysis unit only, you will have to make the decision if you 1. want to bring your certified technology into the unit and meet the ACI measures or 2. take the 50% rule hardship. Remember that taking a hardship in the ACI category will reweight your MIPS score to 85% quality in 2017 and 15% CPIA.

      You may also want to check to see how much they bill out to medicare each year (or how many patients they see). They may be able to meet the low threshold requirements and be exempt from MIPS.

      If they are not exempt from MIPS, you could take the easy road (as Dr. Ketchersid pointed out a few blogs ago) and just submit “something” to avoid the penalty. In this case, you can avoid ACI measures, and just submit 1 quality measure or 1 improvement activity. This route is only available for 2017 but it would easily avoid a penalty. The downside is no possibility for an upward bonus – however, it would probably be a minimal bonus amount for NPs anyways considering how little they may bill compared to a Nephrologist.

      Just food for thought!


  1. Kathie Joseph says


    Does this mean if they meet the measure they will be paid at the same rate as the physicians under their own NPI #? Right now if they bill under their own number we get paid 85%.


    Kathie Joseph

    • Diana Strubler says

      Hi Kathie,

      Meeting the ACIs measures (or any of the MIPS measures) will not affect the way mid-levels are being paid today in the dialysis units.

      Hope you have a happy holiday!


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