Solo practitioners and small practices must earn at least 15 MIPS points this year to avoid any Medicare cuts. Reaching this goal will be relatively easy to accomplish since CMS has established several new provisions to reduce their reporting burden and help them fulfill the requirements. Let’s take a look at who meets the definition of a “small practice” and what flexibilities they can benefit from when reporting MIPS.
What is a Small Practice?
CMS considers a small practice to include solo practitioners and practices with 15 or fewer providers who bill under the same Tax Identification Number (TIN). The CMS Participation Status Tool indicates whether clinicians have small practice special status.
Support Aimed At Small Practices
CMS has provided several accomodations to small practices for the 2018 performance year.
- More Clinicians Are Exempt - CMS increased the low volume threshold to exclude more clinicians from MIPS reporting requirements. Eligible clinicians or groups are exempt if they have less than or equal to $90,000 in Medicare Part B allowed charges for covered professional services OR see 200 or fewer Medicare Part B patients. Providers can check the CMS Participation Status Tool to find out if they are required to report this year.
- Small Practice Bonus - Small practices will have 5 bonus points added to their final MIPS score if they submit data in at least one MIPS performance category.
- 3 Point Minimum Score for Quality Measures - Small practices will continue to receive at least 3 points for Quality measures, even if they do not meet the data completeness requirements. Therefore, you can report 6 quality measures on at least 1 eligible patient to earn 15 points for the Quality category.
- Hardship Exception for Promoting Interoperability (formerly ACI) - Clinicians and groups can apply for a hardship exception, based on being a small practice, to have the Promoting Interoperability category reweighted to 0. The 25% weight would be reallocated to the Quality category. Small practices would need to submit a hardship exception application to CMS by December 31, 2018.
- Double Points for Improvement Activities - Small practices must only complete 1 high-weighted Improvement Activity or 2 medium-weighted Improvement Activities for a minimum of 90 days to receive the full 15 points for this category.
- Virtual Group Reporting - CMS is giving solo practitioners or groups of 10 or fewer the option to join a “virtual group” to report MIPS with other practices. Providers do not need to be in the same specialty or location to form a virtual group. Since providers must elect the MIPS virtual group option prior to the start of the performance period, they can no longer form groups for 2018 MIPS reporting. However, those interested in participating in a virtual group for the 2019 performance period would need to make the election by December 31, 2018.
The Bottom Line
Understanding MIPS requirements, including how to take advantage of the flexibilities offered to small practices, is critical for successful reporting. CMS has simplified reporting for small practices this year so it is easier to earn 15 MIPS points and avoid a negative 5% payment adjustment in 2020. There are a variety of strategies a small practice can utilize to obtain 15 points without spending a lot of time and resources on reporting. The good news is you don’t need to figure this out alone. MDinteractive offers tools and resources to make reporting easy and unlimited customer support to help your practice achieve MIPS compliance.
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