“As you sow, so shall you reap” is an adage we are all familiar with. One interpretation of it that we are creators of our destiny. Good or bad happens to us depending on how we behave. The eastern version of this Biblical verse can be summed in one word – “Karma”. Whichever philosophy you choose to believe in, the underlying message is the same – Your actions today define your tomorrows. This ancient wisdom holds true for MIPS too. Your MIPS performance in 2017 will determine the payment adjustments in 2019. Furthermore, your MIPS score will be linked to your NPI even if you change groups or switch your reporting preferences.
Let us take a closer look at MIPS score portability and how it will work in a few different scenarios.
MIPS Payment Adjustment Identifier - TIN/NPI
Every eligible clinician needs to understand that the 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 under multiple APM entities, which is vital to ensure the clear accountability and portability of MIPS score. The MIPS Payment Adjustment Identifier is of a greater significance to groups in which clinicians' performance is 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 eligible providers would earn the same score and the same payment adjustment.
MIPS payment adjustment will not apply to the clinicians who were excluded from MIPS because of their clinician type, being the new Medicare-enrolled provider, or are identified as a QP or Partial-QP with an Advanced APM.
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 a few providers who are part of a MIPS-APM (scored under APM scoring standard), while rest of the providers are required to report under 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 reporting under MIPS (their performance can be included under MIPS group reporting). 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 could 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 2017 MIPS scores.
- 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 won’t get any payment adjustment in 2019 (positive or negative).
MIPS Score Portability Summarized
Regardless of how you chose to report, your MIPS score will always be linked to your NPI. Even if you change groups, form a new group, choose to report as an individual instead of as part of a group, your MIPS score will stay with you. You will get the positive or the negative payment adjustment based on your performance year MIPS score.
If you happen to have multiple MIPS scores (under different entities) for a single performance year, the payment adjustment will be based on highest MIPS scores you earn.
You can utilize the MIPS Score Simulator to get a complete picture of your practice and formulate the strategy to maximize MIPS score.