By Rebecca Hancock, Flora Lum, MD, Chris McDonagh, Cherie McNett, Molly Peltzman, Jessica Peterson, MD, MPH, and Sue Vicchrilli, COT, OCS
This content was excerpted from EyeNet’s MIPS Manual 2017.
MIPS eligible clinicians can choose to participate in MIPS as individuals or as part of a group.
What is a group? Two or more clinicians, as identified by their National Provider Identifiers (NPIs), would be considered a group if they have reassigned their billing rights to a single Tax Identification Number (TIN).
Pick 1 approach for all MIPS performance categories. A practice that opts to report as a group will be scored as a group for all MIPS performance categories.
Most groups won’t need to register with CMS. You generally can report as a group without first registering as a group. The exceptions are if you plan to report via the CMS Web Interface (see “CMS Web Portal Versus CMS Web Interface”) or the Consumer Assessment of Healthcare Providers (CAHPS) survey. (In both cases, you should have registered with CMS by June 30, 2017.)
Why Report as a Group?
If a practice opts for group reporting, its clinicians pool their MIPS data and the group is scored at the TIN level. All clinicians get the same 2017 MIPS final score and the same 2019 payment adjustment. There are some advantages to this approach.
Improvement activities: Score points with a little help from your colleagues. When you are reporting as part of a group, if at least 1 of your colleagues satisfies the requirements for a particular improvement activity, then the group as a whole scores points for that activity.
ACI: Satisfy the mandatory base score measures as a group. Base score measures are mandatory for ACI. If you are participating in MIPS as an individual, your ACI score will be 0% unless you successfully meet the requirements of all the base score measures. But when you participate as part of a group, if 1 of your colleagues fulfills a base score measure, then everybody in the group is considered to have fulfilled that measure.
Quality: If any subspecialists in your practice struggle to find 6 quality measures, reporting as a group might help. Suppose a practice consists of 4 cataract subspecialists and a pediatric ophthalmologist. The pediatric ophthalmologist might find it a challenge to choose 6 measures to report for herself, but it wouldn’t be a problem for the group as a whole.
Performance rates are calculated for the group as a whole. For a measure that is scored based on your performance rate—such as a quality measure or an ACI performance score measure—the group would aggregate the performance data for all of its clinicians and then just report 1 performance rate.
Group reporting is the default option for IRIS Registry/EHR integration. Because of the advantages of group reporting, practices that integrate their EHR system with the IRIS Registry are automatically set up for MIPS group reporting; they can, however, ask to be set up to report as individuals.
Caveats to Group Reporting
There are some potential downsides to reporting as a group.
Watch the low-volume threshold. Both individuals and groups have the same low-volume threshold for being excluded from MIPS (see “Exclusion 2”). A clinician who fell below that threshold (e.g, she received less than $30,000 from Medicare over a 12-month period) would be exempt from MIPS if reporting as an individual, but she would lose that exemption if reporting as part of a group (assuming that the group exceeds the low-volume threshold).
Clinicians may lose their ACI exemption. Certain types of clinicians, if reporting as individuals, may be exempt from the ACI performance category and would have their ACI score reweighted (see “Some Clinicians May Be Exempt From ACI”). However, if those types of clinicians are reporting as part of a group, they would only retain their ACI exemption if everybody in their group was also exempt.
Claims reporting is not an option for groups. You would need to choose from the other reporting mechanisms (see “Table 2: Select Your Reporting Mechanism(s)”). However, this should not deter you from group reporting, since reporting via IRIS Registry/EHR integration and via the IRIS Registry web portal are both superior options.
Download the CMS Guide
On June 15, CMS published a 43-page guide to participating in MIPS as a group. It describes how groups are assessed and scored under MIPS and how the payment adjustments will be applied; it discusses quality, ACI, and improvement activities from a group’s perspective; and it provides data submission checklists.
Go to https://qpp.cms.gov/about/resource-library and download “Group Participation in MIPS 2017.”
___________________________
Next: Know the Basics: Next Steps
Note: Meeting regulatory requirements is a complicated process involving continually changing rules and the application of judgment to factual situations. The Academy does not guarantee or warrant that regulators and public or private payers will agree with the Academy’s information or recommendations. The Academy shall not be liable to you or any other party to any extent whatsoever for errors in, or omissions from, any such information provided by the Academy, its employees, agents, or representatives.
COPYRIGHT© 2017, American Academy of Ophthalmology, Inc.® All rights reserved. No part of this publication may be reproduced without written permission from the publisher. American Academy of Ophthalmic Executives® and IRIS® Registry are trademarks of the American Academy of Ophthalmology®.