MIPS: Reporting as a Group or as Individual Clinicians
Reporting as a Group or as an Individual – Considerations
- All member of a practice (based on Taxable ID Number – TIN) must participate in the group
- Eligibility thresholds for MIPS are based on the sum of allowed Medicare Part B charges or the sum of Medicare Part B beneficiaries by the practice.
- For example two clinicians that each have less than $90,000 a year in allowed Medicare Part B charges (excluding Medicare Part B drug costs) would not be eligible for the MIPS unless they formed a group and their combined total of Medicare Part B allowed charges was greater than $90,000 per year.
- This should be taken into consideration for practices that have clinicians with variable levels of Medicare Part B allowed charges or patient volumes.
- All clinicians in the group will receive a MIPS score based on the same 6 quality measures. This can present challenges for multispecialty groups. CMS has proposed allowing practices to form subgroups in the 2019 performance year, but this has not been finalized.
- Each individual Improvement Activitiy only need to be performed by one clinician in the group, regardless of group size.
- Forming groups allows for conservation of resources and sharing of the administrative overhead associated with reporting for MIPS.
- Groups of more than 15 clinicians are not eligible for the 5 point small practice MIPS bonus. All clinicians reporting as individuals will receive this bonus
- Groups of more than 15 clinicians will also be measured based on the “All Cause Readmission Measure.” CMS will use performance on the 6 highest performaning Quality measures and the All Cause Readmission Measure to determine the MIPS Quality Performance score.
- Practice have until the reporting deadline to declare whether they wish to report as individual clinicians or as a group
- Practice of 25 or more clinicians may elect to report quality data through the CMS Web Interface, however, if they choose this reporting mechanism they must register with CMS by June 30th of the same performance year.
- Reporting through the claims reporting mechanism is only available to individual clinicians, it not an option for groups reporting for the MIPS.