Healthmonix Advisor

MIPS Hacking: Report as a Group to Maximize ROI

Posted by Mike Lewis on March 14, 2019
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I speak with many organizations who are planning to report MIPS individually, only for their eligible providers. What they fail to realize is that they can achieve significant additional revenue by reporting as a group for all providers in their practices, even those that are deemed ineligible. In these cases I like to do a simple cost comparison to show what organizations are missing out on, and while each case is unique, the results are often striking.

Cost and Revenue

For example, say an organization has 200 NPIs where 50 are eligible (and 150 are ineligible), and the organization makes $10 mil in Medicare revenue — $6 mil from eligible clinicians and $3 mil from ineligible clinicians. Assuming a modest adjustment of, say, +3%, if you report only eligible clinicians you’re looking at a $180,000 increase. If you use a qualified registry like MIPSPRO, your cost may be something around $300 per provider, so in this case the total cost adds up to $15,000, for an overall revenue increase of $165,000.

$6 mil revenue +3% = $180,000 increase

$180,000 - $15,000 cost = $165,000 total revenue increase

That’s not too bad, of course, but if in this hypothetical case our organization reports both eligible and ineligible NPIs, the +3% increase will instead net $300,000. We often charge less per provider for groups with more providers, but if for simplicity’s sake we again assume a cost of $300 per provider (totaling $60,000), our new overall revenue increase will be $240,000!

$10 mil revenue + 3% = $300,000 increase

$300,000 - $60,000 cost = $240,000 total revenue increase

In other words, in this scenario we’ve increased revenue by $75,000 simply by including ineligible clinicians.


RELATED: Predicting the Maximum MIPS Incentive in 2019 and Beyond


Use Case: Individual VS Group Reporting

Those were just ballpark numbers, so let’s look at a more specific example. I recently spoke with an organization that had 2 eligible providers and 40 ineligible, and wanted to know what group reporting might do for them. When I did the math, assuming a reimbursement of +1.88% (and basing the numbers off of 2018 even though the adjustments will be made in 2020), the result spoke for itself:

  Individual Reporting 
(2 Eligible Providers)
Group Reporting
(Whole TIN)
2018 Medicare Charges  $788,945  $3,952,071
 Est. 1.88% Incentive  +$14,832  +$74,299
 Vendor Costs  -$878 -$10,500
 Total  $802,899 $4,015,870
 Estimated Return on Investment  $13,954  $63,799

In other words, group reporting could add nearly $50,000 to this organization’s bottom line.


Administrative Burden

Another major benefit of reporting as a group is the potential to reduce administrative burden. In group reporting, all clinicians across the same TIN will receive the same score (and payment adjustment) for all 4 MIPS categories. This means that the reporting process can prove to be more efficient, since group reporting allows for only one submission rather than a separate submission for each clinician.

Perhaps more significant for your bottom line, though, is the option to report Quality measures that only apply to a subset of your NPIs. Group reporting allows you to use the 6 best measures that maximize the group score, even if those measures do not apply to every clinician in the group. So for example, if you have five dermatologists in the practice that can get a perfect score on certain dermatology measures, you can use the scores of that small subset to benefit the whole group.

Additionally, an entire group can be rewarded when just one provider fulfills the requirements for either the Promoting Interoperability (PI, formerly Advancing Care Information) or the Improvement Activities (IA) categories. If one provider completes a base score measure under PI, and/or is engaged in an IA for at least 90 continuous days, everyone in the group gets credit for fulfilling the measure and/or activity.

If you have questions about what all this might mean for your organization specifically, don’t hesitate to reach out! Schedule time with me here, or get in touch via email ( or by phone (215-330-5256).


Topics: PRO Tips, MACRA & MIPS, ROI