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 2018 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 2018 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 report MIPS at the individual level, one potentially 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 (formerly Advancing Care Information):
- Base score measures are mandatory for PI (ACI). If one participates in MIPS as an individual, the PI score will be 0% unless all requirements for the base score measures are met. But when one participates as part of a group, if another provider in the group fulfills a base score measure, then everybody in the group is considered to have fulfilled that measure.
- Improvement Activities
- All clinicians in the group will receive credit for a specific improvement activity if at least one clinician in the group has been engaged in that activity for 90 continuous days.
- For example, all 6 members of a practice could share on the MIPS points when just one clinician is participating in the systematic anticoagulation program (high weighted Improvement Activity).
- Non-Patient Facing MIPS Group
- A group is considered non-patient facing if >75% of NPIs billing under the group’s TIN during the non-patient facing determination period (9/1/2016 – 8/31/2017; 9/1/2017 – 8/31/2018) 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 (ACI) 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.
- 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).
- Registration for CAHPS was accessible through the PV-PQRS Registration System at https://portal.cms.gov. You will need to a valid EIDM User ID and password to choose your group’s reporting mechanism. No changes are allowed after this deadline.
- 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.