One of the trickiest aspects of the new CMS Quality Payment Program is understanding how to report MIPS as a group. MIPS group reporting is when a TIN of 2 or more providers decides to report their MIPS measures and activities on the group (TIN) level, rather than on the individual (TIN+NPI) level. This could be an advantage to a practice that has a few providers who struggle to find measures that are relevant to them personally, or a practice exercising the "test option" of MIPS reporting for 2017. Eligible Clinicians must report either individually or as a group consistently across all MIPS performance categories.
Reporting at a TIN Level may include clinicians that would otherwise have qualified for an exemption. If reported individually, clinicians who fall below the low-volume threshold of billing ≤ $30,000 in Medicare Part B charges or provide care for ≤ 100 Medicare Part B beneficiaries would be exempt from MIPS. Likewise, clinicians who are newly enrolled in Medicare would be exempt. However, when part of a TIN that is reporting as a group, these clinicians would be included.
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Who is included? |
Who is not included |
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Clinicians who individually qualify for the low volume threshold |
Groups that as a whole bill less than or equal to $30,000 or see less than 100 Medicare Part B beneficiaries. |
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Clinicians who are newly enrolled in Medicare |
Clinicians who do not bill Medicare Part B |
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QPs/ Partial QPs |
Physical / Occupational Therapists, LCSWs, psychologists, and other clinicians that are not be eligible until 2019 |
There are also some caveats to group reporting for two out of the three performance categories of MIPS. The Quality Performance Category has no special circumstances. However, there are conditions in both Advancing Care Information and Improvement Activities that could change the requirement for the category, or allow an individual to be entirely exempt.
When reporting individually, both non-physician eligible clinicians and hospital-based clinicians are exempt from the Advancing Care Information Performance Category. Group reporting will include non-physician providers, but still exclude hospital-based clinicians. The ACI hardship exemption would most likely apply to a whole group as well, although if you have an extreme circumstance, we recommend that you contact the QPP help desk to determine whether or not your group will qualify for a hardship exemption.
If an individual clinician that counts as a non-patient facing clinician reports Improvement Activities, they only have to report half as many activities as a patient facing clinician. Groups reporting Improvement Activities can qualify as non-patient facing groups and therefore subject to the same condition if 75% of the clinicians included in the TIN qualify as non-patient facing. Otherwise, they must report the full amount of Improvement Activities. However, this is still pretty easy, as the Improvement Activity requirements is the same for individuals and groups.