Bhagavad Gita is a scripture that has captured the attention of many spiritually inclined minds around the world because it’s teachings transcend religion. Many people perceive it as a way of living. Although there are many interpretations of the teachings embodied in this sacred scripture, my grandma’s interpretation resonates best with me and is relevant to MIPS: Focus on what is in your control and is going to stay with you. Put in your best and forget the rest. Just like Karma stays with a soul, your MIPS score will stick with you wherever you go. It will always be tied to your NPI even when you change groups or switch your reporting preferences. You may not believe in Karma or the permanence of soul, but if you are a MIPS eligible clinician, you better care about your MIPS score that you are going to carry with you on your journey onward.
MIPS Payment Adjustment Identifier - TIN/NPI
Every eligible clinician needs to understand this well. TIN/NPI combination will serve as their unique payment adjustment ID. This combination can uniquely identify every clinician in a group whether reporting as individuals, groups, or multiple APM entities which is vital to ensure the clear accountability and portability of MIPS score. It is of a greater significance for groups as a clinician’s performance could be included under multiple reporting entities.
One Group, One Payment Adjustment
If you are reporting as a group, your final score will be calculated based on the aggregate performance of all the providers (MIPS eligible and non-eligible) reporting under the group TIN. All the providers get the same score and the same payment adjustment.
Group Reporting as Individuals
If you are part of a group, but report as individuals, then you won’t have a TIN score. Payment adjustment for every eligible clinician would be applied at the NPI level in this case. It is a difficult decision to make. Whether to report as a group or as individuals. MIPS calculators like MyMipsScore can help you make that decision by comparing the scores for both situations.
Same Group, Different Payment Adjustments
There are four scenarios in which the scores for TIN/NPI could vary for a group:
1. If a TIN/NPI is excluded from MIPS
If a group is comprised of MIPS eligible and non-eligible clinicians, the performance of non-eligible clinicians will count towards calculation of the group score in 2017, but they don’t get any score or the related payment adjustment in 2019.
2. If a TIN/NPI has multiple possible scores
This is possible when the clinicians belong to multiple reporting entities in a group. For instance, a TIN can have only certain providers who are part of a MIPS APM, while rest qualify for MIPS. The providers that are part of MIPS APM will have two scores then – (1) For the MIPS APM and (2) For the entire group. Determining the payment adjustment at the TIN/NPI level helps to correctly identify and resolve any overlaps in eligibility without carving out any performance.
3. If a TIN/NPI is new to a TIN
If Dr. John leaves Group-A (TIN-A) and joins Group-B (TIN-B) in middle/end of the performance year 2017, then in the payment year 2019, the payment adjustment for Dr. John will be different than rest of the providers in Group-B who reported for the entire 2017 under TIN-B.
- If Dr. John joins Group-B in 2018, his payment adjustment will be according to the Group-A MIPS score.
- If Dr. John joins Group-B sometime in 2017, his payment adjustment will be according to the highest MIPS score. If Group-B scored higher than Group-A, Dr. John will get the payment adjustment according to Group-B score.
4. The TIN itself is new and therefore doesn’t have historical data associated with TIN/NPI
Let’s say Dr. Ramona left an old and established Group-A to form a new Group-B in 2018 with a couple of her old pals and colleagues from Group-C and Group-D, and some fresh graduates. As Group-B was not in existence in 2017, TIN-B doesn’t have a MIPS score pertaining to that performance period. So, in 2019, all the eligible clinicians in Group-B will have payment adjustments applied according to their scores in 2017.
- The clinicians who reported as individuals in 2017, will get payment adjustment in 2019 based on their individual MIPS score.
- The clinicians who were part of Group-C and Group-D, will get payment adjustment based on TIN-C/NPI and TIN-D/NPI MIPS scores respectively.
- If clinicians who were not MIPS eligible clinicians in 2017 (fresh graduates in a group or excluded professionals), they don’t get any payment adjustment in 2019 (positive or negative).
MIPS Score Portability Summarized
Thus, if you change groups, go from a group to another, chose to report as an individual instead of as part of a group, your MIPS score stays with you. Regardless of how you chose to report, your MIPS score will always be linked to your NPI. You will get the positive or the negative payment adjustment based on your performance year MIPS score. The silver lining is that for a performance year the payment adjustment will be based on highest of all different scores you earn.
MyMipsScore™ helps you focus on what you can control, your MIPS Score. This MIPS calculator app is designed to help you monitor your numbers regularly for all the performance categories, and for all the eligible clinicians so you get a complete picture of your practice and make necessary changes. The patent pending MIPS Score Simulator feature of the app helps you define the strategy to maximize your MIPS score.