MIPS Reporting: Individual vs. Group Reporting and New Year 2 Changes

By Arieanna Schweber

High-growth medical practices know that there can be opportunities hidden in the fine print of every new regulatory program. MIPS — part of the larger transition to value-based care — is one program that offers both carrots and sticks. It’s easy enough to avoid a penalty, but savvy practices are aiming higher and looking at opportunities to earn incentives through MIPS. One decision that has the potential to impact payments is whether to report as an individual or as a group.

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) is positioned to replace the Sustainable Rate Growth (SRG) formula for Medicare payments to providers. The program shifts the way Medicare fees will be paid in 2019 from a service-based model to a performance-based model, which incentivizes the end-value brought to the patient.

MACRA’s value-based reimbursement system is called the Quality Payment Program (QPP) with two paths for participation: the Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs).

Under the Proposed Rule for the Quality Payment Program Year 2, proposed by CMS in late June 2017, if you bill more than $30,000 and care for more than 100 Medicare patients per year, you are subject to MIPS reporting which bega on January 1, 2017. Clinicians can choose how they want to participate in the payment program based on their practice size, specialty, location, or patient population. For the 2017 transition year, MIPS-eligible clinicians can submit a minimum of 90 days of data or a full year of data. Although the revised rule eases the burden on small practices and complex patients with “bonus” points and simplified reporting requirements, QPP implementation is still a major undertaking for small practices.

MIPS-eligible clinicians (physicians, physician assistants, nurse practitioners, clinical nurse specialists, and certified registered nurse anesthetists) will be required to participate in one of two QPP tracks in order to avoid negative payment adjustments up to 4% in 2019, increasing yearly to 9% penalty per practitioner by 2022.

For medical groups, one of the earliest decisions to make is whether physicians should report as individuals or as a group. This decision has the potential to affect how quality metrics are reported and the potential bonuses that are available.

Individual or Group Reporting: Which Is Best For Your Group?

There are potential upsides and downsides to group reporting, depending on the individuals who make up your practice. You also need to determine your goals: Are you looking to avoid a penalty or to reach for a bonus?

Reporting as an individual gives you complete control over personal performance in each category to earn the highest potential incentive. For smaller medical groups, this ensures that individuals who have the highest potential are not pulled down by those with lower performance indicators. Individual reporting for larger groups has the highest administrative burden since each individual must track and report their own data for the Quality, Advancing Care Information, and Improvement Activities categories. Such data can be tracked and submitted in a number of ways, including via CareCloud’s practice management, Central.

Reporting as a group means you are dependent upon the performance of the Eligible Clinicians in your group. When submitting as a group, the threshold of 100 Medical Part B patients is applied to the combined group, so clinicians who would individually not meet this metric would be required to report Quality Metrics (with some exceptions). Although lower-performing individuals will not result in penalties or fee adjustments for the group, low scores could impact potential bonuses.

For the first time, it is possible for small practices of two or more physicians to take advantage of group reporting, as long as the physicians share the same Tax Identification Number (TIN). Small groups that anticipate meeting or exceeding MIPS requirements can benefit from reduced administrative overhead by reporting as a group. Under the QPP Year 2 Proposal, clinicians can elect to participate in MIPS via Virtual Groups, comprised of individuals or small groups who come together “virtually” with at least one other to participate in MIPS. As with standard groups, this reduces the administrative overhead for reporting. Clinicians in a Virtual Group will report across all four performance categories and will be subject to the same requirements as non-virtual MIPS groups.

For larger groups and those looking to improve their chances of high bonus payments, aggregating the scores of many individuals can help providers with a lot of measures to offset those with fewer measures. In this case, reporting as a group helps even out the entire group’s success for measures within each category and makes it easier to reach the bonus requirements.

MIPS is a reflection of one cornerstone of the new medical economy, namely the shift from volume to value. We see MIPS as an opportunity for our clients to be rewarded for delivering outstanding care in their communities with the help of the adaptive, cloud-based health technology at CareCloud. Specialized medical groups rely on the EHR and patient engagement solutions at CareCloud to streamline workflow and improve patient care, leading them on the path to demonstrable improvements in MIPS performance metrics. With CareCloud’s expert client managers, clients have a personalized coach helping them every step of the way.

Additional Requirements for Group Reporting

Under MIPS, there are six data submission mechanisms, including the CMS Web Interface, known formerly as the Group Practice Reporting Option (GPRO) Web Interface for groups of 25 or more Eligible Professionals. Groups reporting via the CMS Web Interface agree to report on all 15 CMS Web Interface measures, as detailed here.

Group reporting may require additional systems, such as a registry, and additional workflows to report quality measures.

CareCloud is working on a partnership with a Qualified Clinical Data Registry (QCDR) that will enable all clients who choose to submit as a group to do so easily. We are planning to make this feature available before the end of Q3.

If you have additional questions, we recommend that you contact the QPP help desk to ensure you are provided the most accurate and up-to-date information related to your inquiry. QPP Service Center can be reached via email at qpp@cms.hhs.gov or by telephone at 1-866-288-8292.


 

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