{"id":2851,"date":"2018-06-28T13:11:08","date_gmt":"2018-06-28T19:11:08","guid":{"rendered":"https:\/\/dsiohn098w.mpqhf.org\/blog\/?p=2851"},"modified":"2018-06-28T13:11:56","modified_gmt":"2018-06-28T19:11:56","slug":"mips-group-reporting-questions-answers","status":"publish","type":"post","link":"https:\/\/dsiohn098w.mpqhf.org\/blog\/mips-group-reporting-questions-answers\/","title":{"rendered":"MIPS Group Reporting Questions & Answers"},"content":{"rendered":"

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MIPS Group Reporting Questions & Answers<\/h1>\n

June 28, 2018<\/h5>\n
Written by \tMiranda Burzinski<\/h6>\n

There are many questions surrounding group participation and the Merit-based Incentive Payment System (MIPS). What makes a group? Who is included in the group? If you aren\u2019t MIPS eligible, are you still part of the group? What if all of the providers in the group don\u2019t have data for ALL of the measures the group chooses to report on? <\/p>\n

There are many questions surrounding MIPS group participation, and in this blog we are going to provide some answers for you.<\/p>\n

What makes a group?<\/strong> A group is defined as a single Taxpayer Identification Number (TIN) with two or more eligible clinicians as identified by their National Provider Identifiers (NPIs) who have reassigned their Medicare billing rights to the TIN.<\/p>\n

Who does the group include?<\/strong> If a TIN chooses to group report it would include all MIPS eligible clinician types (physicians, physician assistants, nurse practitioners, clinical nurse specialists and certified registered nurse anesthetists), regardless if they have met the Low Volume Threshold (LVT) individually or not. Clinicians who are not part of the recognized eligible clinician types can voluntarily report individually, but they must be included in the group if they have reassigned their billing rights to the TIN and the TIN has chosen to group report. Also, an eligible clinician who has assigned their billing rights to the TIN cannot choose to report individually if the remainder of the TIN has decided to participate as a group. <\/p>\n

If you aren\u2019t MIPS eligible are you still a part of the group?<\/strong> The answer is yes. There are four ways that an eligible clinician can be excluded from MIPS: <\/p>\n

    \n
  1. be a newly Medicare-enrolled clinician, <\/li>\n
  2. be a Qualifying APM Participant (QP), <\/li>\n
  3. be a Partial QP, and <\/li>\n
  4. do not exceed the LVT. <\/li>\n<\/ol>\n

    When electing to participate as a group, the determination shifts from the NPI level to the TIN level. If the TIN has exceeded the LVT, all eligible clinician types in the TIN have now exceeded the LVT and are now MIPS eligible, therefore the fourth exclusion does not apply. Even if a clinician fits into an exclusion category, they must still participate with the group if the TIN decides on group participation. <\/p>\n

    What if all the providers in the group don\u2019t have data for ALL the measures the group chooses to report on? <\/strong>The data reported for the group is aggregated across all the providers. This means that not every NPI in the TIN must equally participate in all the measures and categories selected to report. The data selected to report must still meet the same data completeness standards required with individual reporting. <\/p>\n

    What if some providers in the group are excluded from a MIPS category?<\/strong> When choosing to report as a group, instead of individuals, the clinicians who are exempt from a MIPS category (Quality Measures (QM), Improvement Activities (IA), Promoting Interoperability (PI), cost), sometimes referred to as a special status, give up that right to the exemption\/special status. The only time the category exemption still stands would be in the rare circumstance that all eligible clinician types in the group are excluded from the category. New for MIPS in 2018, small clinics, classified as TINs with 15 or fewer NPIs, can apply for an exemption from the PI category. If the exemption is granted the entire group would then be exempt from PI and the category would be reweighted to QM. For small clinics that choose to report individually, each NPI would have to apply for the PI exemption.<\/p>\n

    Who gets the positive\/negative reimbursements?<\/strong> If an adjustment is earned, either positive or negative by the group, it will only be assessed to MIPS-eligible clinician types who are not excluded from MIPS. Newly enrolled Medicare clinicians, QPs and Partial QPs were required to report with the group but are exempt from MIPS Medicare reimbursement adjustments. All clinicians participating in the group will receive a final MIPS score.<\/p>\n

    We hope you now have a clearer understanding on individual versus group participation. We are here to help you weigh the benefits of individual and group reporting so that you make the best choice for your practice. If you would like a more in-depth look at group reporting please go to:
    \nhttps:\/\/www.cms.gov\/Medicare\/Quality-Payment-Program\/Resource-Library\/Group-Participation-in-MIPS-2018.pdf <\/a><\/p>\n

    It is a 52-page resource full of helpful information to provide you with a deeper understanding of group participation. <\/p>\n

    IMPORTANT NOTE:<\/strong> If you plan to use the CMS Web Interface<\/strong> to group report or to participate in the Consumer Assessment of Healthcare Providers and Systems (CAHPS) survey you must register by 7\/2\/18<\/strong>, CMS just extended the previous deadline of 6\/30\/18. To use the CMS Web Interface option for group participation there must be 25 or more NPIs within the group. To register go to https:\/\/qpp.cms.gov\/login<\/a> and log in with your Enterprise Identity Management (EIDM) credentials to access the registration page<\/strong>. If you were registered for the CMS Web Interface in 2017 you are automatically registered in 2018. <\/p>\n

    Email the QPP Help Desk at qpp@cms.hhs.gov<\/a> or call the QPP Service Center at 1-866-288-8292.<\/p>\n

    You are also welcome to visit our Mountain-Pacific QPP website<\/a> for more MIPS details.<\/p>\n

    You can also use the \u201cLeave a Reply\u201d section below, and one of our subject matter experts will get back to you.<\/p>\n

    Other Resource Links<\/strong>
    \n    CMS QPP Website<\/a>
    \n    HTS MIPS Services<\/a>
    \n    MIPS Eligibility – 4 Steps<\/a>
    \n    See all Previous MIPS blogs<\/a><\/p>\n

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