Eligible clinicians (ECs) reporting for the Merit-based Incentive Payment System (MIPS) via Qualified Registry or Qualified Clinical Data Registry (QCDR) can report at the individual level or group level for MIPS in 2017.
Do I have to report MIPS?
Physicians and other clinicians can check their MIPS eligibility here: https://qpp.cms.gov/learn/eligibility
What is Individual Reporting?
ECs reporting at the individual level will be assessed based upon their National Provider Identifier (NPI). Payment adjustments are based on performance across all MIPS categories and will be applied to the individual EC’s Medicare Part B reimbursements in the correlating payment year.
What is Group Practice Reporting?
ECs can report as a group when two or more ECs reassign their billing rights to a single Tax Identifier Number (TIN). Groups are assessed collectively at the TIN level across all MIPS categories and payment adjustments will be applied across the group. To participate as a group via Qualified Registry or QCDR, all ECs within the TIN must be registered with AQI, including CRNAs. Download CMS guidance on group reporting in MIPS 2017 here.
Are there different reporting requirements for individual and Group Practice Reporting?
Requirements for the MIPS performance categories are similar for individual and group practice reporting for both Qualified Registry and QCDR. All ECs, reporting either individually or via group must report:
- All payer data, Medicare and Non-Medicare
- Minimum of 50 percent of all denominator-eligible cases for all measures
- Six measures, including one outcome or other high-priority measure as specified by CMS
- Attest to Improvement Activities equaling 40 points
Please note, those ECs and groups electing to report via QCDR will be able to report ASA QCDR measures and MIPS measures, potentially expanding the pool of applicable measures to report for the MIPS Quality Component. ECs and groups reporting via Qualified Registry can report MIPS measures only.
So, should we report individually or as a group?
There are several factors: unique to each practice, to consider when deciding whether to report individually or via group, including:
- Past Performance: Were clinicians successful in PQRS?
If electing to report as a group, any payment adjustment will be applied at the TIN level to all ECs. If a few ECs fail to meet reporting requirements or have poor performance, this could affect the entire group’s payment adjustment. Note, ECs must notify AQI if they wish to all report via group or all individually.
- Reporting Burden: Can an individual EC successfully meet all reporting requirements? Is it easier to do so as a group?
Specialty ECs may struggle to meet the six-measure requirement and may find it easier to do as a group. Practices should consider how this can shift reporting burden to a select few members of a group. For example, a cardiac anesthesia measure may apply to only two ECs in a large group. Remember, 50 percent of all denominator-eligible cases must be reported for each selected measure.
What if a few clinicians in a group are exempt from MIPS and the rest are not?
If a few clinicians in a practice are exempt from reporting individually, but the group is eligible to report MIPS, practices have a few options.
- All eligible clinicians report individually. In this case, those clinicians exempt from MIPS do not have to report at all. Clinicians that are eligible for MIPS at the individual level, must report and meet reporting requirements as an individual. The low volume threshold for individuals is defined as clinicians with less than or equal to $30,000 in allowed charges or less than or equal to 100 Medicare patients.
- All clinicians report as a group. The entire group must report all data for all clinicians, including those physicians that would have been exempt as individuals. As data are submitted at the TIN level, groups must submit data for the entire group and payment adjustments are applied at the TIN level. The low volume threshold for groups is defined as practices with less than or equal to $30,000 in allowed charges or less than or equal to 100 Medicare patients.
What about non patient-facing and hospital-based clinicians? How do they factor in?
ECs who are deemed non patient-facing or hospital-based status must report Quality and Improvement Activities, but not the Advancing Care Information (ACI) category. For these ECs, the Quality component is reweighted to 85 percent and Improvement Activities remain at 15 percent. Non-patient facing and hospital-based ECs and groups still must report six (6) measures or if there are not six, must report all measures that apply to their patient population. For the Improvement Activities component, activities are reweighted for non patient-facing clinicians, with medium activities equaling 20 points and high weighted activities equaling 40 points. Therefore, non-patient facing ECs can perform two medium-weighted Improvement Activities or one high-weighted Improvement Activity to meet component requirements. Improvement Activities for hospital-based clinicians are scored with standard weights.
An entire group is considered non patient-facing or hospital-based if 75 percent or more ECs fall into these categories. CMS letters noting practice eligibility in MIPS will clarify whether a group is considered non patient-facing or hospital-based entirely or not. Groups should consider the differences in requirements and ability to meet these requirements based on their clinician status and specific practice contingencies.
How should I consider part-time clinicians or locum tenens in my practice?
CMS will notify all clinicians of eligibility in MIPS. If a part-time clinician meets the minimum eligibility requirements, he/she is required to report to MIPS to the same standard of a full-time clinician. Locum tenens are not considered MIPS ECs and they should bill for services they provide using the NPI of the clinician for whom they are substituting.
Who should I contact at ASA or AQI for more information?
Please send MIPS participation and data submission questions to firstname.lastname@example.org.