All of us have experienced the power of teamwork. Often a task can overwhelm one person, but becomes easy when the team tackles it together. MACRA realizes this, and is structured to encourage the team spirit in provider organizations. The incentives are designed to promote coordination and shared responsibility at the group level. Because of the many advantages of group reporting, CMS is working on enabling small practices to create virtual groups. So, if your group TIN is MIPS eligible, you must consider reporting as a group. In order to make the decision, there are certain things you need to understand about group reporting.
Let us establish the terminology to facilitate clear understanding. Here is how the MACRA final rule defines the following:
MIPS Eligible Clinicians: In performance years 2017 and 2018, MIPS would be applicable to physicians (doctors of medicine, doctors of osteopathy and osteopathic practitioners, doctors of dental surgery, doctors of dental medicine, doctors of podiatric medicine, doctors of optometry, and chiropractors), physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists.
Excluded Eligible Clinicians: newly Medicare enrolled MIPS eligible clinicians, QPs and certain Partial QPs participating in Advanced Alternative Payment Models (Advanced APMs), and clinicians that fall under the low-volume threshold (practices or individuals with less than or equal to $30,000 in Medicare Part B allowed charges or
less than or equal to 100 Medicare patients).
Group: A group is defined as a set of clinicians (identified by their NPIs) who have assigned their billing rights to a common Tax Identification Number (TIN), irrespective of specialty or practice site. This group must comprise of two or more eligible clinicians, and include at least one MIPS eligible clinician, as identified by the NPI. (Eligible clinicians are the clinicians who would have been included in MIPS had the exclusion criteria not been applied.)
1. Requirements to Report as a Group
When reporting as a group:
- The performance data will need to be aggregated across the TIN for all clinicians
- All eligible clinicians will have their performance assessed as part of a single TIN and thus will have the same MIPS score.
- Will be assessed as a group across all MIPS performance categories
- Must meet the definition of group at all times during the performance period
2. Meet the Volume Threshold Collectively
One advantage of group reporting is that services provided by all the individual NPIs within the TIN, (excluded eligible clinicians and MIPS eligible clinicians) counts towards meeting the volume threshold and would count towards performance and score determination.
However, it is noteworthy that payment adjustment based on the 2017 group MIPS score will not apply to the newly Medicare enrolled MIPS eligible clinicians, QPs, and certain Partial QPs.
3. One TIN – One Score
MIPS score is determined not on the volume of data reported or the duration for which it is reported, but on the performance rate. By the very definition of the group, MACRA encourages clinicians to work together to drive the performance rate up. Higher performance rate would lead to a higher score.
An important detail to keep in mind is that when you report as a group, even the clinicians in the group who were below the volume threshold get the payment adjustment. Group reporting could help you earn more incentive dollars.
4. One Submission Method per Performance Category
A group needs to pick one submission method for each performance category. Quality performance category carries the most weight and has the most submission options. In addition to EHR, Registry, and Qualified Clinical Data Registries (QCDRs), groups of any size offering primary care can use CAHPS for MIPS as one quality measure. Larger groups of 25 or more providers can also use CMS Web Interface to submit their data.
5. Entire Group Reports on the Same Measures
For each performance category, the entire group has to pick the measures that works for them and earns the group the highest score possible. That’s the tricky part, especially for a multi-specialty group. Luckily there is a solution for that. MyMipsScore allows you to add all the pertinent quality measure for the entire group and then evaluate which measures turn out to be the best for your group as a whole. Additionally, it enables you to perform predictive analytics to determine the optimum performance required for different measure-submission method combination to maximize your score.
For the Quality performance category, size of your group also determines the number of measures that your group is required to report and submission method options available. For groups of 16 or more eligible clinicians, an additional All-Cause Hospital Readmission Measure (ACR) would be calculated from their claims data for the entire reporting year.
6. Same Reporting Period
For every performance category, the entire group needs to report for the same reporting period. Different 90 continuous days can be chosen to report different performance categories within the same calendar year though. The last 90 continuous day window will begin on Oct 2nd 2017. But if you wait till the last minute, you lose the opportunity to put the process in place, identify the areas of improvement, and make required adjustments to put your practice in the best possible position. You need continuous monitoring to determine the best reporting period for the entire group.
7. Important Deadlines
If your will report one quality measure via CAHPS for MIPS Survey, or utilize CMS Web Interface submission method, you will need to register your group by June 30th, 2018 to utilize these options. CMS has great resources that explain these two group reporting options in depth.