More and more doctors are leaving their practices. According to The Physicians Foundation, only a third currently identify as independent practice owners or partners; in 2012, this number was closer to 50%. While some of this shift can be attributed to retirement and career change, many are instead leaving their private practices in order to become employees of hospital-owned practices and multi-specialty clinics. The number of practices owned by hospitals and health systems has risen 86% between 2012 and 2015, and the number of U.S. physicians employed by hospitals and health systems has increased 50% in that same period.And it’s easy to see why this kind of change might be appealing. More than half of physicians often experience burnout, and a salaried position with a larger group or hospital can look like an escape from the intense administrative burden that comes with running your own practice. But if you are among the providers planning to make this kind of change, there’s something you should keep in mind:
Your MIPS score will follow you.
As you may know, a group under MIPS is defined as a single Tax Identification Number (TIN) with two or more eligible clinicians (including at least one MIPS eligible clinician). When you become a hospital employee or otherwise change to a new Tax Identification Number (TIN) it may seem like a fresh start, but in fact your past MIPS performance will follow you from your previous practice, and the reimbursement received by the hospital for your service will be impacted by that performance for the next two years. This means your own future compensation and payment may still be impacted by what you report this year.
- 2017 MACRA Quality Payment Program Final Rule
Changing practices during a performance period
As CMS explains, if you bill Medicare Part B charges under more than one group (TIN) during the performance period, you are required to participate in MIPS for each TIN association except in cases where those TINs are excluded under MIPS. If you start working for a new practice or create a new TIN that did not previously exist during the performance period, there is no historical performance information or final score for the new TIN/NPI. Since there is no final score, CMS will use the NPI performance for the TIN(s) the NPI was billing under during the performance period. In other words, if you work in your current practice during the performance period but then at a new practice during the payment year, CMS will use the final score for the old practice to apply the MIPS payment adjustment for the NPI in the new practice. If you are billed under more than one TIN during the performance period, and start working in a new practice or create a new TIN, CMS will take the highest final score associated with your NPI in the performance year.
How to protect yourself
As we’ve seen, changing to a new TIN does not erase performance history under MIPS. So even if you are planning to make such a change, we advise that you still take steps to at least partially comply with MIPS in 2017.
RELATED: The Absolute Minimum Required for MIPS Success
If you don’t know where to begin, Healthmonix provides several resources which you can explore for free to get a better sense of what is required of you under MIPS. Check out our MIPS Learning Center for the basics, or dive into the details with our MIPS Resource Library and our blog, The Healthmonix Advisor. Once you have a good idea of what you’ll need to report and how, we recommend that you consider the system your current practice uses to collect and report data. Is that system equipped to reflect the good work you have already done and help you earn the score you deserve? Even if you plan to change practices within the next year, the time to find out is as soon as possible.
