Ugh. MIPS Means Dual Attestation for Some Providers

Meaningful Use Medicaid Providers who also have Medicare Billings ...

Here is an interesting question we just researched from a community member of our MIPS Preparation Portal:

"I know that MIPS specifically excludes Medicaid, but what about my Meaningful Use Medicaid providers who also have Medicare Billings?"

This appears to be one of those Unintended Consequences that pop up in big regulations.

We looked closely and could find no explicit language addressing this issue. So providers are left with following the basic guidelines of both programs. Here is how it breaks down:

1. Meaningful Use Medicaid providers will have to attest with their individual states, as long as they are receiving stimulus payments. Once a provider's stimulus payment stream has been exhausted, the only reason to attest would be to protect any Medicare billings from Meaningful Use Penalties. Since those penalties go away after 2018 due to MIPS, State-level attestation can eventually go away.
2. Any provider who has Medicare Billings above a $10,000 threshold must comply with MIPS, which includes Meaningful Use Attestation.

So, it looks like some of us might need to Attest twice, unless CMS puts something into the Final Rule in November, accepting a "feed" from States. However, since the data States currently provide to CMS does not include detail numerators and denominators (which are required to calculate a MU MIPS score), dual attestation is a likely option.

Join our MIPS Preparation Portal here. You will find a number of useful downloads, and enable free access to our expert staff who can research the regulations on your behalf for answers to all your MIPS questions.

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