Eligible clinicians may participate in MIPS as individuals or as part of a group. Providers planning to report MIPS as group can use MDinteractive as a registry for 2020 MIPS. Group reporting is available for groups of 2 or more providers that bill with the same tax identification number.
Registering was a group with CMS is not necessary unless the group is planning to do the CAHPS for MIPS survey.
Requirements for Group Participation
Groups that choose to participate at the group level must:
- Meet the definition of a group during the performance period for the MIPS payment year.
- Aggregate their performance data across the TIN to have their performance assessed and scored as a group.
MDinteractive Qualified Registry - Submission Mechanism Checklist:
- Create an account with MDinteractive
- Choose measures and/or activities.
- Sign the MIPS Group Reporting consent form online or download and fax it to MDinteractive at 866-251-4069.
- Report/attest data for the 2020 calendar year.
Advantages of reporting MIPS at the group level instead of individual level
- There is no need to choose measures that apply to all clinicians in a multispecialty group practice. Let's imagine a practice with one anesthesiologist, one pathologist, one hospitalist, one internist, one dermatologist and one cardiologist. If the providers reports MIPS at the individual level, one would need to manage and optimize the performance of 36 different quality measures. At the group level, one could report just the 6 best measures. The combination could be 2 anesthesia measures, 2 pathology measures and 2 hospitalist measures. One just needs to report the patients/visits eligible for the chosen measures. For example, Measure #187 (Stroke and Stroke Rehabilitation: Thrombolytic Therapy) will only apply for patients discharged by the hospitalist. Please note that there are measures that apply to patients seen by different specialties: for example Measure #226 (Tobacco Use: Screening and Cessation Intervention) will apply to all outpatient office visits done by the internists, dermatologists and cardiologists.
- Promoting Interoperabilty:
- When one participates as part of a group, if at least one provider in the group fulfills an objective or measure then everybody in the group is considered to have fulfilled that measure and will benefit from the additon to the score. Many of the new eligible clinician types do not use CEHRT, if part of the group's TIN these EC's would receive the same PI category score as the rest of the clinicians in the group.
- Improvement Activities
- New in 2020: For group reporting, the participation threshold is increased from a single clinician to 50% of the clinicians in the practice. At least 50% of a group’s NPIs must perform the same activity for the same continuous 90 days in the performance period
- For example, all 6 members of a practice could share on the MIPS points if at least three clinicians are participating in the systematic anticoagulation program (high weighted Improvement Activity).
- Non-Patient Facing MIPS Group
- A group is considered non-patient facing if more than 75% of NPIs billing under the group’s TIN during the non-patient facing determination period (10/1/2018 – 9/30/2019; 10/1/2019 – 9/30/2020) are labeled as nonpatient facing.
- Non-patient facing MIPS groups receive full credit for IAs by selecting one high-weighted IAs or two medium-weighted IAs.
- Non-patient facing groups will qualify for reweighting of the Promoting Interoperability (formerly Advancing Care Information) performance category.
- Hospital-based MIPS eligible clinicians l Physician assistants l Nurse practitioners l Clinical nurse specialists l Certified registered nurse anesthetists
- Groups have the option to include or not include Promoting Interoperability (PI) performance data from the above MIPS clinicians that qualify for an automatic PI reweighting: Groups will be automatically reweighted if ALL of their clinicians (clinician types noted above) qualify. If ANY clinician within the group does not qualify for a reweighting, the group must submit PI data to CMS.
- Groups are considered hospital based if more than 75% of the clinicians billing under the practices TIN met the definition of hospital based (based on POS codes 19, 21, 22 and 23).
- CAHPS for MIPS Survey Option with Registry Reporting
- The CAHPS for MIPS survey is optional for groups with 2 or more eligible clinicians and is not provided as an option for individual clinicians. The CAHPS for MIPS survey is not appropriate for practices that do not provide primary care services (for example, a group of surgeons).
- PY 2020 CAHPS for MIPS Survey Registration is Now Open: Sign in to QPP and register through Manage Access
- If your group selects the CAHPS for MIPS survey as one of the quality measures to report, your group will:
- Select and authorize a CMS-approved survey vendor (from a list published by CMS) to collect and report your survey data to CMS;
- Be responsible for your vendor’s costs to collect and report the survey;
- Monitor your vendor’s performance during survey administration;
- Receive your CAHPS for MIPS survey scores from CMS; and
- Have your CAHPS for MIPS survey scores available for public reporting on Physician Compare.