Even an overwhelming task becomes easier when tackled as a team. Same holds true for MIPS. Reporting as a group might not only be beneficial for reduction of administrative burden and meeting the case-minimums, but it might also help increase performance rates and the total positive payment adjustment. In the light of these benefits, group reporting has been made available to small practices from 2018 in form of virtual group option. So, if your group TIN is MIPS eligible, you must evaluate the group reporting option.
First, there are certain things you need to understand about group reporting.
Let us establish the terminology to facilitate clear understanding. Here is how the QPP Final Rule defines the following:
Eligible Clinicians: For 2018 performance year, 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: Bill $90,000 or less in Medicare Part B allowed services only OR Provide care to 200 or fewer Medicare Part B beneficiaries
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 2018 group MIPS score will not apply to the newly Medicare enrolled MIPS eligible clinicians, QPs, and certain Partial QPs.
3. One TIN - One MIPS 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.
4. MIPS Payment Adjustment
When you report as a group, even the clinicians in the group who were below the volume threshold get assigned the same MIPS score and hence the payment adjustment. Group reporting could help you earn more incentive dollars.
However, if the clinicians in your group participate in a MIPS-APM too (which would a separate TIN), the MIPS-APM score would take precedence over the group MIPS score when calculating MIPS payment adjustment for 2020. [ Read: MIPS Score Hierarchy for Payment Adjustment Calculation ]
5. 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.
6. 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.
7. 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 for PI and IA performance categories within the calendar year. 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.
8. CAHPS for MIPS and CMS Web Interface
To report one quality measure via CAHPS for MIPS Survey, or utilize CMS Web Interface submission method, you had to register your group by June 30th, 2018 for the 2018 MIPS performance year to utilize these options. Similarly, for 2019 MIPS performance year, the registration deadline is June 30th, 2019.