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MIPS Reporting: Why You Should Consider Reporting As A Group

Posted on October 6, 2020
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If you have two or more clinicians billing with the same Tax Identification Number (TIN) in your practice, you should consider reporting MIPS as a group to gain some administrative relief and possibly increase your chances for success. According to CMS data, the majority of practices are choosing to report as a group. There are many reasons why group reporting is the preferred option for clinicians. Let’s take a look at what group reporting means, and why it may benefit your practice.

Group Reporting - How it Works

You can report MIPS as a group if your practice has 2 or more providers billing under the same TIN throughout the entire performance period. When you report as a group, data is aggregated across the TIN. All clinicians under your TIN will report together and the practice will be assessed as a group across all MIPS categories (Quality, Promoting Interoperability, Improvement Activities and Cost). Each clinician in the group will receive the same MIPS score and payment adjustment based on the group’s performance.

CMS continues to increase the MIPS reporting requirements each year, so in 2020 you will have to report more to satisfy the program requirements. This year, eligible clinicians and groups must achieve 45 MIPS points (up from 30 MIPS points in 2019) to avoid any penalty. Group reporting can make it easier to reach the higher threshold, in addition to providing many other advantages to your practice.

Important:  If data is submitted both as an individual and a group, you will be evaluated as an individual and as a group for all performance categories, but your payment adjustment will be based on the higher score.

Group Reporting is Easier

When reporting MIPS as a group, your practice can monitor and report fewer measures, saving time and resources so clinicians can focus on patient care instead of paperwork. Consider how group reporting could positively impact a multi-specialty practice consisting of 10 MIPS eligible clinicians from several different specialties, including internal medicine, dermatology, hospitalists, and pathology.

MIPS CategoryIndividual ReportingGroup Reporting

Quality

6 Quality measures reported per provider (60 total measures reported - 6 measures x 10 providers).

6 Quality measures reported for the TIN (e.g., 2 dermatology measures, 2 pathology measures and 2 hospitalist measures).

The group does not have to choose measures that apply to all clinicians in the practice.

Promoting Interoperability

Each provider attests to PI.

The group attests to PI.

The measure numerators and denominators for all MIPS eligible clinicians with data in your 2015 Edition CEHRT will be aggregated.

Clinicians in the group who are not using CEHRT would receive the same PI score as the group.

The group can submit a "yes" for the measures in the Public Health and Clinical Data Exchange objective as long as 1 MIPS eligible clinician is in active engagement with the registry.

Improvement Activities

Each provider attests to IA.

The group attests to IA.

All providers receive credit for an IA if at least 50% of the clinicians in the group perform the same activity during any continuous 90-day period, or as specified in the activity description, within the same performance period.

CMS Submission

10 separate CMS submissions for each NPI/TIN combination.

1 CMS submission for the TIN.

Efficiencies can be achieved for each of the MIPS categories when you report as a group:

  • Quality - Reporting as a group allows you to report just 6 Quality measures, regardless of how many providers practice under your TIN. If you are a multi-specialty practice, you can choose measures that apply to a subset of clinicians to narrow the patient population you must report.
  • Promoting Interoperability (PI) - All of the PI measure data in CEHRT is aggregated (numerator and denominator) across the TIN and reported for at least 90 days. Any clinicians in your practice who are not using CEHRT will still benefit from the group’s PI score.
  • Improvement Activities (IA) - Attesting to this category is simplified since the entire practice will receive credit when at least 50% of the clinicians in the group perform the same activity during any continuous 90-day period (or as specified in the IA description) within the same performance period.

Maximize Your MIPS Score

Your practice can report on your 6 best measures to maximize your group score. In our example of the multi-specialty practice, if the dermatologists performed poorly on the dermatology measures, the practice could report higher scoring measures performed by different specialists to improve the group’s score.

Group reporting is also helpful for subspecialists who may not be able to find 6 Quality measures to report as individuals or can’t meet the case minimum for some measures if reporting on their own. There is a better chance these providers will have sufficient data to report when the data is aggregated for the entire practice.

Financial Rewards

When reporting as a group, any positive payment adjustment or bonus is based on your group’s performance and would be spread across the entire TIN, including clinicians who couldn’t earn an incentive if they had reported as individuals (e.g., due to the low volume threshold). The maximum bonus is estimated by CMS to be 6.25% for clinicians that reach a MIPS score of 100 for their 2020 MIPS reporting, so the potential incentive can be significant for an entire group. Let’s do the math for a physical therapy practice of 25 providers, where only 5 providers are MIPS eligible:

 

Individual Reporting (5 MIPS Eligible NPIs)

Group Reporting (all 25 NPIs in the TIN)
Medicare Part B Allowed Charges for Professional Services$455,000.00$2,235,000.00
Estimated Maximum Bonus (6.25%)+$28,437.50+$139,687.50
Estimated Registry Costs-$1,745.00-$8,725.00
Estimated Financial Reward+26,692.50+$130,962.50


Even when you factor in the estimated costs to report with a registry like MDinteractive, the practice still comes out ahead. The maximum possible bonus for this practice would be nearly five times the amount when reporting as a group than it would have been if only reporting for its MIPS eligible clinicians.

Group Reporting Makes Sense

Reporting MIPS as a group has many advantages to consider, especially as the reporting requirements become more stringent each year and will impact your bottom line. It can save you time and resources by reducing your administrative burden, while allowing you to maximize your scoring and reimbursement potential for a positive outcome. Our MIPS specialists are available to answer your questions so you can decide if group reporting makes sense for your practice.

MIPS Reporting Group reporting MIPS Threshold MIPS Financial Rewards

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