This content was excerpted from EyeNet’s MIPS 2019; also see the Academy’s MIPS hub page.
The impact of some MIPS regulations depends on the size of your practice.
How CMS determines practice size. CMS determines how many eligible clinicians are in a practice by reviewing claims data and looking at the number of National Provider Identifiers (NPIs) associated with the practice’s Tax Identifier Number (TIN). This would include NPIs of eligible clinicians who are not MIPS eligible clinicians—see Who Does (and Doesn’t) Take Part in MIPS.
Next, it designates practice size as follows:
- Small practices have 15 or fewer eligible clinicians.
- Large practices have 16 or more eligible clinicians.
What claims data does CMS look at? In determining practice size for the 2019 performance year, CMS looks at claims data from the MIPS determination period, which consists of two time segments:
- 1, 2017–Sept. 30, 2018 (with a 30-day claims run out)
- 1, 2018–Sept. 30, 2019 (no claims run out)
Has CMS designated your practice as small or large? Check online by using the QPP Participation Status lookup tool.
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